US: IRS grants six-month filing extension for Exempt Organisation Business Income Tax Return
The US Internal Revenue Service (IRS) has granted certain applicable entities that are making an elective payment election a six-month automatic extension of time to file an original or superseding Form 990-T, Exempt Organisation Business Income Tax
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Malaysia exempts capital gains tax on share disposal for restructuring, IPOs
Malaysia’s Ministry of Finance (MoF) announced gazette orders exempting capital gains tax (CGT) on the capital gains or profits from the sales of shares during company restructuring and initial public offering (IPO) restructuring
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Russia clarifies transfer pricing rules for foreign entities with permanent establishments
Russia’s Ministry of Finance (MOF) has issued a guidance letter No. 03-12-12/1/59174 clarifying the transfer pricing obligations for controlled transactions involving foreign legal entities operating through permanent establishments (PEs) in
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Taiwan publishes guidance on deductible interest rates for low or no interest loan
Taiwan’s National Taxation Bureau of the Northern Area (NTBNA), under the Ministry of Finance,stated that, if a company borrows money to pay interest on the one hand, but does not charge interest on the loan money on the other hand, or the
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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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Taiwan clarifies withholding tax rules
Taiwan's Ministry of Finance has released a notice detailing the revised withholding tax rules, which were approved on 7 August 2024 and will come into effect on 1 January 2025. To enhance the protection of the rights and interests for tax
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UAE extends corporate tax filing deadline
The UAE Federal Tax Authority (FTA) has extended the deadline for filing corporate tax returns and settling corporate tax obligations to 31 December 2024. The announcement was made in Public Clarification CTP004, clarifying the implications of FTA
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Turkey clarifies application of new anti-avoidance rule
The Turkish Revenue Administration has issued Income Tax General Communiqué No. 326 in the Official Gazette, outlining application measure of Law No. 7524. The purpose of this communiqué is to introduce a general anti-avoidance rule, which
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France sets new interest rates for shareholder interest deductibility
France has published interest rates for entities whose financial year (FY) ended between 30 September and 30 December 2024, which are used to determine the deductibility of interest payments to shareholders. The applicable rates from 30 September
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Australia consults expansion of penalty laws for tax exploitation scheme promoters
Australia’s government is requesting feedback on proposals to expand the penalty laws for promoters of tax exploitation schemes. The Treasury released the public consultation document on 4 October 2024, and interested stakeholders are
See MoreMalaysia consults on tax treatment of local ships
The Inland Revenue Board of Malaysia (IRBM) initiated a public consultation on a draft ruling regarding the tax treatment of Malaysian ships and the exemption of shipping income for qualifying residents. The consultation is open for comments from
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Brazil consults Qualified Domestic Minimum Top-Up Tax
Brazil’s Federal Revenue Service has initiated a public consultation regarding the additional social contribution to net profits (Contribuição Social Para o Lucro LÃquido, CSLL). The consultation will be open from 4 October to 10 November,
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Poland approves cash accounting scheme for eligible entrepreneurs
Poland’s parliament approved a new "Cash PIT" regime aimed at individual entrepreneurs who operate their businesses independently and whose revenue did not surpass the PLN 1 million (EUR 250,000) threshold in the previous tax year. The scheme
See MoreAustralia issues law companion ruling on corporate collective investment vehicle regime
The Australian Taxation Office (ATO) released the Law Companion Ruling (LCR) 2024/1 - The Corporate Collective Investment Vehicle Regime on 2 October 2024. Effective from 1 July 2022, this Ruling is about amendments made to the taxation law to
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OECD: Tax Arbitrage Through Closely Held Businesses
On 7 October 2024 the OECD published a taxation working paper with the title Tax arbitrage through closely held businesses: Implications for OECD tax systems, written by Tom Zawisza, Sarah Perret, Pierce O’Reilly and Antonia Ramm. The working
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Chile: Parliament passes tax compliance bill
Chile’s Chamber of Deputies have passed the Tax Compliance Bill (Proyecto de Ley de Cumplimiento de las Obligaciones Tributarias). Earlier, Chile’s Senate approved the Tax Compliance Bill on 24 September 2024 which included key changes to
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EU publishes its stance on Terms of Reference for a United Nations Framework Convention on International Tax Cooperation
The Council of the European Union has declared its Position of the European Union and its Member States on the draft Terms of Reference for a United Nations Framework Convention on International Tax Cooperation. This follows after they abstained
See MoreRussia to increase corporate income tax rate on interest from government securities
The Russian government has decided to raise the corporate income tax rate on interest earned from government and municipal securities by 5%. The proposed amendments are included in bill No. 727330-8, which has been submitted to the State Duma on
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