US: IRS clarifies CFC not eligible for dividends received deduction under section 245A
The US Internal Revenue Service (IRS) issued an Office of Chief Counsel memorandum clarifying that a controlled foreign corporation (CFC) is not eligible for a dividends received deduction under section 245A. This memorandum provides
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Chile updates tax compliance law, introduces changes to GAAR, transfer pricing, and CFC
Chile's Internal Revenue Service (SII) has announced that the Law on Compliance with Tax Obligations (Law No. 21.713) has been published in the Official Gazette on 24 October 2024. General and Special Anti-Avoidance Rules changes The General
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US: Congressional Research Service reviews mortgage interest deduction
The Congressional Research Service (CRS) released the In Focus report (IF 12789 ) at the US Library of Congress on 22 October 2024. This report analysed the mortgage interest deduction, highlighting policy options that Congress may
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UN: Resolution on Negotiating Committee for Framework Convention for International Tax Cooperation
On 14 October 2024 a Resolution was drafted by Nigeria on behalf of the Africa group at the UN, to adopt the terms of reference for the UN Framework Convention on International Tax Cooperation. The draft Resolution referred to the work of the Ad Hoc
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Latvia updates list of tax havens, removes Antigua and Barbuda
Latvia announced an updated list of low-tax and tax-free jurisdictions in the Official Gazette on 23 October 2024. This list, derived from the latest EU list of non-cooperative jurisdictions, notes the removal of Antigua and Barbuda, effective 1
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UN Tax Committee: Tax, Trade and Investment Agreements
On 17 October the UN Tax Committee discussed issues around the interaction of tax, trade and investment agreements. Guidance on tax and investment agreements Following the presentation of draft guidance on the relationship of tax and
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UN Tax Committee: Issues in Extractive Industries Taxation
On 15 October 2024 the UN Tax Committee discussed developments in their work on extractive industries taxation. The work of the relevant subcommittee has focused on the energy transition; the valuation of mining products for tax purposes; and tax
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UN Tax Committee: Transfer Pricing Issues
On 16 October 2024 the UN Tax Committee discussed transfer pricing issues. The transfer pricing subcommittee presented for approval a paper on dispute resolution addressing the implementation of advance pricing agreement (APA) programs. The
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El Salvador releases tax havens lists for 2025
El Salvador's Ministry of Finance released the updated General Guide on preferential tax regimes (tax havens) on 27 September 2024, detailing jurisdictions and territories considered tax havens for the 2025 fiscal year, including low and no-tax
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Australia: ATO consults new restructuring, thin capitalisation, debt deduction creation rules
The Australian Taxation Office (ATO) launched a public consultation on Practical Compliance Guideline (PCG) 2024/D3 - Restructures and the new thin capitalisation and debt deduction creation rules on 9 October 2024. The ATO has published the
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Chile: Parliament passes tax compliance bill
Chile’s Chamber of Deputies have passed the Tax Compliance Bill (Proyecto de Ley de Cumplimiento de las Obligaciones Tributarias). Earlier, Chile’s Senate approved the Tax Compliance Bill on 24 September 2024 which included key changes to
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Taiwan introduces CFC De minimis rule for profit seeking enterprises
Taiwan's Ministry of Finance has announced a de minimis test enabling profit-seeking enterprises to avoid recognizing investment income under the CFC Rules on September 2024. The National Taxation Bureau of the Southern Area, Ministry of Finance
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France sets interest deductibility rate limit for shareholder payments
France’s Ministry of Finance released the quarterly TMP (taux moyen pratiqué) rate to determine the annual market rate limit for deducting interest paid to shareholders. French law allows corporations to deduct annual shareholder interest
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Ireland named amongst top 10 tax havens globally
According to the Tax Justice Network's latest ranking report published on 1 October 2024, Ireland has surpassed the Bahamas to become the ninth-largest tax haven in the world. A spokesperson for Ireland's Department of Finance has denied that the
See MoreChile passes tax compliance bill with income, VAT, transfer pricing measures
Chile’s Senate has approved the Tax Compliance Bill on 24 September 2024, which will be presented to the Lower House for final approval. The newly approved tax measures include modifications to the general anti-avoidance rule (GAAR), statute of
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Australia: ATO publishes guidance on approved forms for thin capitalisation tests
The Australian Taxation Office has issued guidance regarding the approved form that allows taxpayers to choose between the group ratio test and the third-party debt test. This form is used when making a choice to apply the group ratio test or
See MoreAustralia endorses OECD subject to tax rule for multinational tax reform
Andrew Leigh, the Australian Assistant Minister for Competition, Charities, and Treasury, announced that Australia is committed to multinational tax reform through a Statement of Support for the OECD's 'Subject to Tax Rule' on 20 September
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Russia updates list of jurisdictions without adequate information exchange for CFC purposes
The Russian Federal Tax Service is in the process of completing a draft order that will update the list of jurisdictions lacking sufficient tax information exchange with Russia. This new list will supersede the Order No. ED-7-17/914 @ of 1 December
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