Czech Republic updates non-cooperative jurisdictions list for CFC rules
The Czech Republic Ministry of Finance issued the Financial Bulletin No. 3/2024, on 28 February, 2024, which contains an updated notice regarding the list of non-cooperative jurisdictions concerning the Czech Republic's Controlled Foreign Company
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Russia: MoF clarifies tax exemption for CFC amid treaty suspensions
The Guidance Letter No. 03-12-11/2/11449, published by the Russian Ministry of Finance (MoF) on 12 February, 2024, addresses the tax exemption applicable to profits of Controlled Foreign Companies (CFCs) situated in jurisdictions with which Russia
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Australia publishes guidelines to address amendments to thin capitalisation rules
The Australian Taxation Office (ATO) published on Friday, 10 May, 2024, a list of priority public advice and guidance topics regarding the modifications to the thin capitalisation rules. Additionally, the ATO mentioned that it will update the
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Sweden considers new permanent residency rules for taxation
Sweden's Ministry of Finance announced, on 3 May, 2024, a significant update regarding permanent residency criteria for tax purposes. Following the release of a memorandum by the Tax Agency in November, 2023, proposing a redefinition of permanent
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Italy introduces CFC substitute tax measures
Italy’s Revenue Agency has published provisions for Controlled Foreign Company (CFC) substitute tax option, released as part of Legislative Decree No. 209 of 27 December 2023. Legislative Decree No. 209 outlines measures for adopting the Pillar
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Taiwan: Ministry of Finance relaxes taxation for CFC
The Ministry of Finance in Taiwan has released a notification regarding eased taxation regulations concerning profits from Controlled Foreign Corporations (CFCs) invested in enterprises situated in non-low-tax jurisdictions that are acknowledged
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UN: Ad Hoc Committee Discusses Issues for Early Protocols
Following an earlier Resolution on international tax cooperation and a report by the Secretary General setting out options going forward, UN Resolution 78/230 of 22 December 2023 established an ad hoc intergovernmental committee to draft terms of
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UN: Ad Hoc Committee on Framework Convention Discusses Substantive Elements
UN Resolution 78/230 of 22 December 2023 established an ad hoc intergovernmental committee to draft terms of reference for a UN framework convention on international tax cooperation. The first session of the ad hoc committee is being held between 26
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Australia proposes laws on interest limits, foreign investment fees, and taxation for general insurers
The Australian Parliament has recently approved the following bills, which are awaiting Royal Assent. The bills are as follows: The Treasury Laws Amendment (Making Multinationals Pay Their Fair Share—Integrity and Transparency) Bill of 2023
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Chile passes tax compliance bill with updated GAAR rules
On 10 April 2024, Chile's Chamber of Deputies passed the Tax Compliance Bill, which includes numerous tax measures aimed at improving tax compliance in Chile. The newly approved Bill also changes the Chilean tax code. The Senate must approve the
See MoreAustralia: ATO releases discussion paper on thin capitalization rules for foreign bank branches
On 17 April 2024, the Australian Taxation Office (ATO) published a discussion paper regarding the safe harbor formula for calculating the minimum capital requirements for inward investing deposit-taking institutions (ADIs) under the thin
See MoreAustralia offers additional guidance on new thin capitalization rules
On 8 April 2024, the Australian Taxation Office (ATO) declared additional consultations about the guidance for the new thin capitalization rules by the Treasury Laws Amendment (Making Multinationals Pay Their Fair Share-Integrity and Transparency)
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Ukraine issues controlled foreign companies (CFC) notification requirements
On 28 March 2024, the State Tax Service of Ukraine released a notice directed to companies and individuals residing in Ukraine, detailing their duty to report on controlled foreign companies. This notification outlines the requirement for
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France updates non-cooperative states and territories list
The French General Tax Code's list of non-cooperative States and territories (NCSTs) was updated via Decree on 16 February 2024 and published in the Official Journal on 17 February 2024. The list includes the following 16 states and territories:
See MoreSweden: MoF proposes updates to pillar 2 global minimum tax rules
On 19 March 2024, the Swedish Ministry of Finance (MoF) released proposed amendments to the Act on Additional Tax, aimed at incorporating the Pillar 2 global minimum tax as outlined in Council Directive (EU) 2022/2523. As per the proposal, a
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UN: Tax Committee Discusses a New Combined Treaty Article on Services
The 28th session of the UN Committee of Experts on International Cooperation in Tax Matters is being held from 19 to 22 March 2024. The digital economy subcommittee in its workstream B has been considering the function and relevance of physical
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UN: Tax Committee Discusses Tax Issues in the Digitalised Economy
The 28th session of the UN Committee of Experts on International Cooperation in Tax Matters is being held from 19 to 22 March 2024. On 19 and 20 March 2024 the discussions included tax issues in the digital economy. Fast Track Instrument The
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UN: Tax Committee Discusses Extractive Industry Tax and Other Issues
The 28th session of the UN Committee of Experts on International Cooperation in Tax Matters is being held from 19 to 22 March 2024. The meeting is taking place in a global situation of inequality, as countries deal with challenges from increased
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