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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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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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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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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