OECD: Facilitating the Use of Treaty Exchanged Information for Non-Tax Purposes
Sharing of treaty-exchanged information with relevant law enforcement agencies for non-tax purposes helps to combat illicit financial flows (IFFs), money laundering and corruption. Institutions often face operational challenges in implementing this
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OECD: Subject to Tax Rule
On 17 July 2023 the OECD published details of the subject to tax rule (STTR) developed by the Inclusive Framework on BEPS as part of Pillar Two of the two-pillar proposals on international tax. The STTR gives jurisdictions the right to “tax
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OECD: Template for GloBE Information Return
On 17 July 2023 the OECD published details of the contents of the GloBE information return (GIR) under Pillar Two. The GIR is designed to collect the information needed by the tax administration to arrive at an appropriate risk assessment and to
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OECD: Outcome Statement on the Two Pillar Solution
On 11 July 2023 an Outcome Statement on the two-pillar international tax solution was approved by 138 member jurisdictions of the Inclusive Framework on base erosion and profit shifting. The Outcome Statement summarises the package of deliverables
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OECD Report to the G20 Financial Ministers and Central Bank Governors
On 17 July 2023 the OECD published the report prepared for the meeting of G20 finance ministers and central bank governors held in India on 17 and 18 July 2023. Update on the Two-Pillar International Tax Solution The report noted that on 11
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OECD: Consultation on Amount B of Pillar One
On 17 July 2023 the Inclusive Framework issued a consultation document asking for stakeholder input on Amount B under Pillar One. Comments are invited by 1 September 2023. Amount B applies to baseline marketing and distribution activities, which
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OECD Tax Talk Outlines Progress on Two Pillar Proposals
An OECD Tax Talk held on 19 July 2023 summarised recent developments on the two-pillar international tax proposals. Pillar One – MLC The implementation of Pillar One will require a multilateral convention (MLC) to ensure that the
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US: IRS publishes practice units on interest expense limitations
On 16 May 2023, the IRS Large Business and International (LB&I) division issued two practice units in relation to interest expense limitations for related party loans. Interest Expense Limitation on Related Foreign Party Loans Under IRC
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OECD: Tax Transparency In Latin America 2023
On 27 June 2023 the OECD published Tax Transparency in Latin America 2023, during the latest meeting of the Punta del Este initiative. The Punta del Este Declaration aimed to tackle tax evasion and avoidance and other financial crimes by promoting
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Uganda: Minister of Finance presents Budget for 2023/2024 to the Parliament
On June 15, 2023, the Ugandan Minister of Finance, Planning, and Economic Development, Mr. Matia Kasaija, presented the budget for financial year 2023/2024 to the Parliament. On that day, Income Tax (Amendment) Bill 2023 was also passed which was
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UK: Second Reading of Spring Finance Bill 2023
On 13 June 2023 the UK government published the Tax Information and Impact Notes for government amendments at the report stage of the Spring Finance Bill 2023. The Bill includes the following measures: Multinational Top-up tax: UK adoption of
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UAE clarifies interest deduction rules
On 23 May 2023, the United Arab Emirates (UAE) Ministry of Finance (MoF) published Decision No. 126 of 2023 on the general rules for limiting the deduction of interest for corporate tax purposes. To determine the deductible interest from taxable
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IMF: Mining Revenues and Inclusive Development in Guinea
An IMF working paper on Mining Revenues and Inclusive Development in Guinea by A. Badel and R.F. Lyngaas was published on 29 April 2023. The working paper looked at the potential benefits from increasing the taxation of the foreign extractive
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OECD: Consultation Document on Transfer Pricing Issues for Bauxite
On 10 May 2023 the OECD published a consultation document with the title Determining the price of minerals: A Transfer Pricing Framework – Schedule A: Bauxite. This document follows on from the OECD’s toolkit outlining a transfer pricing
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OECD: Progress Report to G7 Finance Ministers on Tax Cooperation
On 11 May 2023 the OECD published a progress report on tax cooperation for the G7 Finance Ministers and central bank governors. A report on these issues had been produced in 2022 and the G7 Finance Ministers asked the OECD to continue its work on
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Brazil publishes law extending certain CFC benefits
On 13 April 2023, Law No. 14.547 transposing Provisional Measure 1148/2022 into law was published in the Brazilian Official Gazette, which extends certain benefits in regard to the controlled foreign company (CFC) rules under Law 12,973/14. Under
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Singapore: IRAS updates e-Tax Guide on the general anti-avoidance provision and its application
On 31 Mar 2023, the Inland Revenue Authority of Singapore (IRAS) published the second edition of its e-Tax Guide concerning The General Anti-Avoidance Provision and its Application. The updated guide includes the following main purposes: First,
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Australia releases exposure draft bill on new thin cap rules
On 16 March 2023, the Australian Treasury issued the Exposure Draft on the earnings before interest, taxes, depreciation, and amortization interest limitation rules (EBITDA). Consultation closes on 13 April 2023. The proposal to change the
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