Belgium: Government presents tax reform plan to parliament, includes VAT measures
The Belgian Chamber of Representatives has released a policy note on 24 April 2025 detailing its tax reform plans for the upcoming year. The key measures of the tax reform plan include: Dividends received deduction rules Enhancing the
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Argentina sets rules for using reconstruction bonds to pay taxes and customs debts
Argentina’s tax authority (ARCA) has announced the regulations for companies and individuals to use Bonds for the Reconstruction of a Free Argentina (BOPREAL) to settle tax and customs debts through General Resolution 5675/2025 on 16 April
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Australia updates form, instructions for thin capitalisation test choice
The Australian Taxation Office (ATO) has updated its form and instructions for taxpayers on 13 February 2025, allowing individuals to select either the group ratio test or the third-party debt test (thin capitalisation test choice) for a specific
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Australia: ATO targets thin capitalisation in trust reviews
The Australian Taxation Office (ATO) has announced on 30 January 2025 regarding its focus on the updated thin capitalisation rules as part of its justified trust reviews. Thin capitalisation in focus for justified trust reviews How we're
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Australia: ATO consults implementation of thin capitalisation third-party debt test
The Australian Taxation Office (ATO) has initiated a public consultation regarding the implementation of the thin capitalisation third-party debt test . Additionally, it addresses the associated Schedule 3 of Draft Practical Compliance Guideline
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Slovenia proposes changes corporate income tax law
Slovenia's government has presented a draft bill (EVA: 2024-1611-0039) to the parliament on 25 October 2024, proposing several amendments to the corporate income tax law. Tax loss carry-forward limitation The bill suggests limiting the
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New Zealand introduces tax policy work programme
New Zealand’s Minister of Revenue has introduced a tax policy work programme on 13 November 2024, which aims to simplify tax and reduce compliance costs, address integrity risks, and improve fiscal sustainability to rebuild the economy. The
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Colombia: DIAN mandates certification for third-party debts under thin capitalization rules
The Colombian tax authority (DIAN) issued Ruling 803 of 23 September 2024, released on 1 November 2024, which provides guidance on the necessary certification of third-party debts for interest deduction purposes under the thin capitalization
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Australia: ATO issues guidance on thin capitalisation rules, related provisions
The Australian Taxation Office (ATO) released guidance on 3 November 2024, outlining how the thin capitalisation rules interact with other provisions. The thin capitalisation rules limit the amount of debt deductions you can claim. Regard must
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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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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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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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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
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Australia 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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Armenia lowers Central Bank refinancing interest rate
Armenia’s Central Bank has lowered the refinancing interest rate from 7.75% to 7.50%. This marks the sixth rate reduction in 2024, following a previous drop of 9.25%. The Central Bank's refinancing rate influences the deductible interest on
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Brazil plans to increase taxes to fund extended social contribution regime
Brazil’s Finance Minister Fernando Haddad has reportedly unveiled plans to raise levies on interest on equity and the social contribution on profits (CSLL). The tax hike is aimed to offset the costs associated with the partial extension of the
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Australia: Guidance on Thin Capitalisation Rules Published Online
Following the enactment of the new thin capitalisation laws in April 2024, the ATO has developed web guidance to assist taxpayers in applying the new rules, which are effective for income years commencing on or after 1 July 2023. Under the rules,
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France: Tax Authority updates interest deduction rates for shareholder loans
The French tax authority has updated the interest rates used to define the deductibility of interest payments made to shareholders. These updates are pertinent to companies with fiscal years ending between 31 December, 2023, and 29 June,
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