Australia: 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
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Australia 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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Namibia announces 2024/25 budget with new tax measures
On 28 February 2024, Namibia delivered the 2024/25 Budget. The key tax provisions in the budget statement include: Individual income tax The 2024/25 Budget increases the threshold for the individual income tax from NAD 50,000 to NAD 100,000,
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Australia: ATO deliberating on amended interest limitation rules
On 30 January 2024, the Australian Taxation Office (ATO) announced that it is seeking public input and feedback on guidance and advice related to the amendments to the interest deduction limitation rules, also known as thin capitalization rules.
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Armenia: Central bank lowers refinancing interest rate
On 12 December 2023, the Armenian Central Bank announced that it lowered the refinancing interest rate from 9.5% to 9.25%. This is the fifth interest rate reduction for 2023. The previously reduced refinancing interest rates are as follows:
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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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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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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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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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Australia seeks feedback on amendments to interest limitation rules
On 18 October 2023, the Australian Treasury Department opened a consultation on an exposure draft bill to amend the interest limitation rules. As part of the 2022-23 Budget, an integrity measure was announced to address risks to Australia’s
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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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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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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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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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Belgium amends guidance on interest deduction rule
On 12 January 2023, Belgium issued Circular 2023/C/8, which provides instructions on the application of the 30% of EBITDA interest deduction limitation starting from 1 January 2019, in line with the EU Anti-Tax Avoidance Directive (ATAD). A summary
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Ireland: Government publishes Finance Bill 2022
On 20 Oct 2022, Ireland’s Minister for Finance Paschal Donohoe published the Finance Bill 2022 as part of the Irish budget. The Finance Bill contains new tax measures that were not included in the budget presented in September 2022. The main tax
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Australia: Consultation on Multinational Tax Integrity and Tax Transparency
A consultation launched by the Australian government on 5 August 2022 sets out measures that would help to address tax avoidance by multinational groups. Comments are invited by 2 September 2022. The package would implement part of the
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