Argentina issuing bonds for state reconstruction
On 22 December 2023, the Argentine government issued Decree No. 72/2023 concerning the Bonds for the Reconstruction for a Free Argentina or Bonos para la Reconstruccion de una Argentina Libre (BOPREAL). The Argentine Central Bank will issue BOPREAL
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Cyprus: Special contribution for defence on interest reduced to 17%
Cyprus has decreased the Special Contribution for Defence rate on interest from 30% to 17%, which will be effective from 1 January 2024. This contribution rate is applicable to all individuals and companies receiving or credited with interest. The
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Italy: CFC rules related to GloBE pillar 2 amended to include 15% tax rate option and substitute tax
On 19 December 2023, Italy's Council of Ministers passed a legislative decree to enforce the tax reforms related to international taxation. This includes implementing the Pillar 2 global minimum tax under Council Directive (EU) 2022/2523 of 14
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Belgium proposes new draft law for CFC rules
The Belgian government has submitted a new draft bill to parliament for implementing stricter rules concerning the taxation of the undistributed income of a controlled foreign company (CFC), shifting from model B (targeting tax avoidance
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Brazil proposes to modify interest on net equity for 2024
On 30 November 2023 and 5 December 2023, Brazil’s Valor Econômico newspaper published a report stating that the Ministry of Finance of Brazil has completed the draft of a new proposal to amend the Interest on Net Equity (INE) mechanism. The
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Germany: MOF issues draft guidance on anti-tax avoidance measures
On 30 November 2023, the German Ministry of Finance (MoF) issued draft guidance on anti-tax avoidance measures targeting non-cooperative jurisdictions. This follows the 2021 Tax Haven Defense Act, responding to EU guidelines against harmful tax
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UN Adopts Resolution to Set Up a Framework Convention on Tax
On 22 November 2023 the UN general assembly adopted a resolution to commence the process of setting up a framework convention on tax. The framework convention could ensure that the UN is the main body for decision-making on international tax
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Australia: Government releases amended interest limitation rule
On 28 November 2023, the Australian government released the amendments and a supplementary explanatory memorandum to the interest limitation rules within the Treasury Laws Amendment (Making Multinationals Pay Their Fair Share—Integrity and
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Russia: FTS updates non cooperative Jurisdictions list for CFC purpose
On 14 November 2023, the Federal Tax Service (FTS) is in the process of updating its list of jurisdictions that do not meet Russia's standards for tax information exchange. The list of countries that do not cooperate with Russia on tax matters
See MoreRussia: MOF publishes tax policy plans for 2024
On 2 November 2023, the Ministry of Finance in Russia released a statement regarding the tax policy proposals announced by State Secretary and Deputy Minister of Finance, Alexey Sazanov, during a recent event hosted by the B1 company. The statement
See MoreOECD Releases Information and Statistics on Mutual Agreement Procedures
On 14 November 2023 the OECD released the 2022 Mutual Agreement Procedures (MAP) Statistics, covering 133 jurisdictions worldwide. The release of these statistics each year is part of the actions to improve dispute prevention and resolution in line
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OECD: Peer Review Report on Tax Transparency and EOI in Poland
On 8 November 2023 the Global Forum on Transparency and Exchange of Information for Tax Purposes published the second-round peer review report on Poland’s implementation of the standard on transparency and exchange of information (EOI). Poland’s
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OECD: Peer Review Report on Transparency and EOI in Thailand
On 8 November 2023 the Global Forum published a peer review report on Thailand's implementation of the standard on transparency and exchange of information. Thailand joined the Global Forum in 2017 and made efforts to establish the necessary legal
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South Africa: SARS issues updated guide on taxation
On 1 November 2023, the South African Revenue Service (SARS) issued an updated guide on taxation. This guide providing a high-level overview of the most significant tax legislation administered in South Africa by the Commissioner for the South
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Pakistan: Peer Review Report on Exchange of Information and Transparency
On 8 November 2023 the Global Forum published the second-round peer review report assessing Pakistan’s practical implementation of the standard on transparency and exchange of information on request (EOIR). The latest peer review assessment
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OECD: Consultation on Transfer Pricing Issues Relating to Lithium
On 6 November 2023 the OECD and the Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF) released for public consultation a draft toolkit with the title Determining the Price of Minerals: Application to Lithium. The
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OECD: Guidance on Transfer Pricing Issues for Bauxite
Following the completion of a previous consultation, on 6 November 2023 the OECD published a toolkit with the title Determining the price of minerals: A Transfer Pricing Framework – Schedule A: Bauxite. This toolkit follows on from the publication
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OECD: Practice Note on Transfer Pricing for Minerals
On 6 November 2023 the OECD published the final version of a practice note with the title Determining the price of minerals: A Transfer Pricing Framework. The practice note has been developed after consultation with interested parties with the aim
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