New Zealand issues draft guidance on loss carry forward rules
The New Zealand Inland Revenue has issued draft guidance interpreting the loss carry forward rules established in 2020, known as the business continuity test (BCT). This new draft aims to clarify anti-avoidance provisions not addressed in the
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Russia proposes tax on excess bank profits
Russia is set to introduce a new one-time tax on banks' excess profits following a surge in financial sector earnings. The bill (No. 728613-8) is to be presented to the State Duma on 1 October 2024 by Budget Committee deputy chairman Aleksandr
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Hong Kong lowers interest rate on tax reserve certificates
The Inland Revenue Department of Hong Kong announced, on 4 October 2024, that starting from 7 October 2024, the new annual rate of interest payable on Tax Reserve Certificates will be 0.8000% against the current rate of 0.8833%, i.e. the new rate
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Croatia consults amendments to General Tax Act: Shareholders to be considered as guarantors for failing to file
Croatia’s government has published proposed amendments to the General Tax Act and launched a public consultation. The consultation is set to conclude on 24 October 2024. Once enacted, the amendment will take effect on 1 January
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Singapore consults on Pillar Two Minimum Tax regulations
Singapore aims to introduce streamlined methods for companies to calculate their top-up taxes in line with the proposed global minimum tax. The global minimum tax, or Pillar Two, aims to establish a 15% effective tax rate for multinational
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US: IRS publishes list of entities, branches with qualified intermediary status
The US Internal Revenue Service (IRS) published its list of entities and branches that have achieved qualified intermediary (QI) status under the Foreign Account Tax Compliance Act (FATCA). The Qualified Intermediary (QI) Program administers
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Taiwan introduces CFC De minimis rule for profit seeking enterprises
Taiwan's Ministry of Finance has announced a de minimis test enabling profit-seeking enterprises to avoid recognizing investment income under the CFC Rules on September 2024. The National Taxation Bureau of the Southern Area, Ministry of Finance
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Australia announces GIC and SIC rates for Q2 2024-25
The Australian Taxation Office (ATO) announced the general interest charge (GIC) rates and shortfall interest charge (SIC) rates for the first quarter of the 2024-25 income year on 16 September 2024. For the quarter commencing on 1 October 2024,
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New Zealand: IRD updates compliance guide for multinational enterprises, incorporating BEPS and pillar two measures
The Inland Revenue Department (IRD) New Zealand has updated its compliance focus guide for multinational enterprises (MNEs) to reflect important changes since 2019, including the integration of OECD base erosion and profit shifting (BEPS) measures
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Slovak Republic passes bill to introduce financial transaction tax, amends VAT, income tax and other tax rates
Slovak Republic’s parliament passed a government bill on 3 October 2024 introducing a new tax on financial transactions and amending several acts, including VAT and income tax rates. The key details of the bills are as follows: Financial
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US: Treasury announces over USD 2 billion in credit transfers for Inflation Reduction Act Phase Four
The US Treasury released a speech outlining the implementation of phase four, along with a press release announcing a significant milestone for clean vehicles on 1 October 2024. Phase Four of Implementation of the Inflation Reduction Act’s
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Nigeria gazettes VAT modification order 2024, introduces new fiscal incentives for oil and gas sector
Nigeria’s Federal Ministry of Finance has unveiled two major fiscal incentives aimed at revitalising Nigeria's oil and gas sector on 2 October 2024. These are Value Added Tax (VAT) Modification Order 2024, which has been published in the
See MoreUS: IRS direct file to expand to 12 states, cover more tax situations for 2025 filing season
The US Internal Revenue Service released IR-2024-258 on 3 October 2024, announcing that Direct File will be available for the 2025 tax filing season in double the number of states than last year’s pilot, and it will cover a wider range of tax
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Brazil implements Additional Social Contribution to Net Profit as Pillar 2 top-up tax
Brazil has enacted Provisional Measure No. 1.262 of October 3, 2024, and Normative Instruction No. 2.228 of October 3, 2024, to introduce an Additional Social Contribution to Net Profit (CSLL). This initiative aims to comply with the requirements of
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European Commission refers Spain, Cyprus, Poland, Portugal to court for failing to transpose Pillar Two Minimum Taxation Directive
The European Commission (EC) decided to refer Spain, Cyprus, Poland, and Portugal to the Court of Justice of the European Union for failing to notify measures for the transposition into national law of Council Directive (EU) 2022/2523 of
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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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Argentina extends tax amnesty opt-in deadlines
Argentina’s Executive Branch issued Decree 864/2024, which extends the deadlines to opt for the tax amnesty regime, published in the Official Gazette of 30 September 2024. The tax amnesty regime was introduced by Law 27,743 setting new
See MoreNigeria gazettes new withholding tax regime
Nigeria’s Federal Ministry of Finance has announced the Deduction of Tax at Source (Withholding) Regulations 2024 has been published in the official gazette on Wednesday 2 October 2024. The commencement date of the new Regulations is 30
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