Italy enforces pillar two global minimum tax
On 28 December 2023, Italy published the Legislative Decree n. 209 dated 27 December 2023 in the Official Journal. The Decree announces the implementation of the EU Minimum Tax Directive (Council Directive (EU) 2022/2523 of 14 December 2022) in
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Russia: FTS updates list of jurisdictions that do not exchange proper information for CFC purpose
On 10 January 2024, the Russian Federal Tax Service (FTS) published updated list of jurisdictions that do not exchange tax information with Russia (Decree No. ЕD-7-17/914). The list pertains to the tax exemption for profits of controlled foreign
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Slovakia parliament passes law to implement pillar two global minimum tax
On 8 December 2023, the Slovak Parliament approved legislation to enforce a top-up tax to ensure minimum taxation for large local entities and multinational groups. The legislation aligns with the OECD Pillar Two and the EU global minimum tax
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Greece reveals draft law on Pillar 2 global minimum tax for multinationals
On 9 January 2024, Greece's Ministry of Economy and Finance declared the presentation of a draft law to the cabinet for integrating the Pillar 2 global minimum tax according to Council Directive (EU) 2022/2523 of 14 December 2022. The draft law
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Australia: ATO plans draft taxation ruling on royalties
On 17 January 2024, the Australian Taxation Office (ATO) announced that it started consultation on a new Draft Taxation Ruling TR 2024/D1 Income tax: royalties - character of payments in respect of software and intellectual property rights. The new
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Spain drafts final legislation to implement pillar 2 global minimum tax
Spain’s Ministry of Finance reveals that it is working on the final legislation for the implementation of the Pillar 2 global minimum tax in accordance with Council Directive (EU) 2022/2523 of 14 December 2022. The current consultation on the
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Malaysia publishes capital gains tax return form filing programme
On 15 January 2024, The Inland Revenue Board of Malaysia (IRBM) announced that it had published the Capital Gains Tax Return Form (CGTRF) Filing Programme. Malaysia's Finance (No. 2) Act of 2023 has introduced new regulations regarding the
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World Tax Brief: January 2024
Belgium International-CFC: The government proposes stricter rules on taxing undistributed income of controlled foreign companies, shifting from anti-avoidance to targeting passive income in the EU Anti-Tax Avoidance Directive. Double taxation
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Philippines: BIR clarifies withholding tax made by online payment platforms
On 15 January 2024, the Philippines Bureau of Internal Revenue (BIR) published the Revenue Memorandum Circular No. 8-2024 of 15 January 2023, in which it clarified the imposition of the new 1% withholding tax for payments by online platforms to
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Norway enacts global minimum tax pillar 2 and amends tax administration act and tax payment act
On 12 January 2024, Normay announced the Supplementary Tax Act in the Official Gazette, which provides the provisions for implementing the Pillar 2 global minimum tax. This includes the introduction of the Pillar 2 income inclusion rule (IIR) to
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Zambia enacts tax amendments outlined in the budget 2024
On 22 December 2023, Zambia took a significant step in reshaping its fiscal landscape by enacting various amendment acts to implement the 2024 budget tax changes. The key highlights of these tax measures include: Income Tax Adjustments:
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Kazakhstan broadens special retail tax regime qualifying activities
On 12 January 2024, Kazakhstan's State Revenue Committee released the Government Decree No. 1240 of 29 December 2023. The Government Decree came into effect on 15 January 2024. This Decree of the government outlines the types of activities for
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Argentina: National congress mulls new Incentive regime for major investments
The Argentine National Congress is evaluating a draft legislation to establish a new incentive regime for major investments by sole purpose vehicles in specific sectors. The sole purpose vehicles for the new incentive regime include corporations,
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Saudi Arabia: ZATCA extends tax penalty relief measures until 30 June 2024
On 29 December 2023, Saudi Arabi’s Zakat, Tax and Customs Authority (ZATCA) announced the extension of the "Cancellation of Fines and Exemption of Penalties initiative until 30 June 2024. ZATCA stated that the initiative's extension, which ends
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India: CBDT issues guidelines for withholding tax on e-commerce transactions
On 28 December 2023, the Central Board of Direct Taxes (CBDT) issued guidelines clarifying the deduction of withholding tax in e-commerce transactions under Section 194-O of the Income-tax Act, 1961. The details of the guidelines are outlined as
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Luxembourg publishes municipal rate multipliers for 2024
On 9 January 2024, the Luxembourg Administration of Direct Tax (Administration des Contributions Directes) released a newsletter regarding the municipal rate multipliers (coefficients) for the 2024 tax year. These coefficients were initially
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Belgium approves 2024 budget Introducing new CFC rules
Belgium has approved the 2024 budgetary measures, including new CFC rules, increased progressive tax on credit institutions, and strengthening Cayman tax rules. New CFC rules One key aspect of Belgiam’s CFC rules is the implementation of the
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France enacts 2024 finance law with global minimum tax rules
On 30 December 2023, France released its Finance Law for 2024 (Law no. 2023-1322) in the Official Gazette, along with the Constitutional Court's review, affirming the constitutionality of key tax measures. A major highlight is the implementation of
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