Ireland clarifies interest deductions for connected party loans
Irish Revenue has published a new Tax and Duty Manual – Part 36-00-19 Interest on loans to defray money applied for certain purposes 27 November 2024, providing guidance on section 840A TCA 1997. Section 840A is an anti-avoidance provision
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Switzerland: Federal Council recommends rejecting loss carryforward time limit extension
The Swiss Federal Council announced the adoption of a dispatch proposing legislation to extend the loss carry forward period from seven years to 10 years on 27 November 2024. The draft law responded to a motion submitted by Parliament, motivated by
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Taiwan: Ministry of Finance announces withholding tax system optimisations, effective 1 January 2025
To optimise Taiwan’s income tax withholding system and protect the rights and interests of taxpayers, amendments to the Income Tax Act, announced on 7 August 2024, will be promulgated on 1 January 2025, as approved by the Executive Yuan. The
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Hong Kong consults tax breaks for asset, wealth management
The Hong Kong SAR (HKSAR) government released a consultation paper to selected stakeholders, seeking their feedback on proposed improvements to the preferential tax regimes. These enhancements focus on funds, family-owned investment holding vehicles
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Singapore enacts Multinational Enterprise (Minimum Tax) Act, Income Tax (Amendment) Act
Singapore has enacted two tax laws, Income Tax (Amendment) Act 2024 and Multinational Enterprise (Minimum Tax) Act 2024, with the aim to align with global tax standards, enhance business competitiveness, and introduce targeted incentives for
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US: IRS and Treasury propose rules on taxed earnings, basis adjustments
The US Internal Revenue Service (IRS) and Treasury Department have issued proposed regulations (REG-105479-18) on 2 December 2024, addressing previously taxed earnings and profits (PTEP) of foreign corporations and the associated basis
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Angola proposes new tax compliance, registration rules in 2025 budget
Angola’s government had submitted the 2025 State Budget Law on 31 October 2024 with various tax measures. The proposed tax measures state that: Non-compliant taxpayers will still face restrictions on financial transactions and work permit
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Argentina scraps advance PAIS tax on imports
Argentina’s tax authority (ARCA) has announced that it eliminated the 95% advance payments of the PAIS tax (Impuesto Para una Argentina Inclusiva y Solidaria) on foreign currency purchases for imports, effective 25 November 2024. This is
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UK: House of Commons debates Finance Bill 2024-25
UK’s Finance Bill 2024-25, which is based on the Autumn Budget 2024, underwent its second reading debate in the House of Commons on 27 November 2024. This followed its initial introduction and first reading on 6 November 2024. The bill passed
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Germany: Fourth Bureaucracy Relief Act updates transfer pricing documentation requirements
The Fourth Bureaucracy Relief Act, which goes into effect on 1 January 2025, brings major updates to transfer pricing documentation requirements in Germany. This latest amendment brings the following changes: Transfer pricing documentation
See MoreUS: Congressional Research Service updates report on global intangible low-taxed income
The US Congressional Research Service (CRS) has released an updated report (IF 11943) addressing proposed changes to the taxation of global intangible low-taxed income (GILTI) on 25 November 2024. The updates explain that the proposed changes
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Turkey reduces corporate tax exemption rate on asset sales
Turkey's government issued Presidential Decision No. 9160 on 27 November 2024, reducing the exemption rate for corporate income tax on gains derived from the sale of certain assets. Presidential Decision No. 9160 came into effect on the day it
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Guatemala proposes simplified tax plans for handicrafts, agriculture
Guatemala’s Congress has passed Decree 31-2024, which includes “The Law for the Integration of the Primary and Agricultural Sector,” on 19 November 2024. This proposal shall establish two streamlined special tax regimes: The production and
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US: IRS provides transitional relief for payment app transactions
The US Internal Revenue Service has issued Notice 2024-85 corresponding to a news release (IR-2024-299) on 26 November 2024, providing transition relief for third-party settlement organisations (TPSOs), also known as payment apps and online
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Hong Kong to exempt crypto taxes for hedge funds, family offices
Hong Kong intends to eliminate taxes on investment gains from cryptocurrencies and other alternative assets to benefit hedge funds, private equity firms, and family offices; according to a circular by Hong Kong’s Financial Services and the
See MoreArgentina announces new interest rates for late tax payments
Argentina’s Federal Tax Authority (ARCA) announced the new interest rates in Auction Rate Securities (ARS) applicable to late tax payments for the period from 1 December 2024 to 31 January 2025. The rates have been calculated in accordance with
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Japan tax revenue expected to reach record high
Japan’s tax revenues are set to hit a record high for the fifth straight year. Projections estimate revenue rising from JYP 69.6 trillion to around JPY 73.4 trillion for the current fiscal year ending in March 2025. The increase, driven by
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Malaysia updates global minimum tax, Labuan self-assessment rules in Finance Bill 2024
Malaysia’s Deputy Minister of Finance has presented the Finance Bill 2024 and the Labuan Business Activity Tax (Amendment)(No. 2) Bill 2024 to the Parliament, on 19 November 2024, proposing amendments to the Income Tax Act 1967 (ITA), Real
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