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
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Nigeria 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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Denmark: 2024-25 legislative plan proposes updates to minimum tax, transfer pricing to match OECD rules
Denmark's government announced the legislative programme for the parliamentary year 2024-25 on 1 October 2024. The bill follows up on the government platform "Responsibility for Denmark" from December 2022 and the agreement on "A Stronger Business
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US: IRS consults tax form for reporting Partner’s Report of Property Distributed by a Partnership
The US Internal Revenue Service (IRS) issued a news release (IR-2024-249) on 30 September 2024 requesting public comments on draft Form 7217 and Instructions for draft Form 7217. On 28 August 2024, the IRS posted a revised draft Form 7217 with
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Malaysia exempts qualifying unit trusts from capital gains, foreign income tax
Malaysia has exempted qualifying unit trusts from capital gains and foreign income tax, issued the Income Tax (Unit Trust) (Exemption) Order 2024 and the Income Tax (Unit Trust in Relation to Income Received in Malaysia from Outside Malaysia)
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France: Prime Minister proposes increased taxation on large corporations
France's Prime Minister, Michel Barnier, has proposed several tax measures aimed at reducing the national debt as part of his draft budget, which include a temporary tax on large corporate profits and a new tax on share buybacks, according to Le
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Ireland named amongst top 10 tax havens globally
According to the Tax Justice Network's latest ranking report published on 1 October 2024, Ireland has surpassed the Bahamas to become the ninth-largest tax haven in the world. A spokesperson for Ireland's Department of Finance has denied that the
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Chile announces tax submission deadlines for 2025
Chile’s Internal Revenue Service (SII) issued Resolution Ex. SII No. 91-2024 on 12 September 2024, outlining the deadlines for submitting various tax forms in 2025. The resolution went into effect on the date of publishing. The forms and
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Chile passes tax compliance bill with income, VAT, transfer pricing measures
Chile’s Senate has approved the Tax Compliance Bill on 24 September 2024, which will be presented to the Lower House for final approval. The newly approved tax measures include modifications to the general anti-avoidance rule (GAAR), statute of
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Poland: Lower parliament evaluates draft law to enact Pillar Two global minimum tax
Poland's Sejm (lower house of parliament) is currently reviewing a draft law, submitted on 25 September 2024, to implement the Pillar Two global minimum tax in accordance with Council Directive (EU) 2022/2523 from 14 December 2022. The draft law
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Cyprus sets deadline for ultimate beneficial owners information
The Department of Registrar of Companies and Intellectual Property (DRCIP) of Cyprus has declared that all companies and partnerships registered under the Companies Law, including European Public Limited Liability Companies, should log into the UBO
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Brazil extends tax incentives for semiconductor industry
Brazil has extended the tax incentives for the semiconductor and information and communication technology sectors until 31 December 2029, published in Law No. 14.968, dated 11 September 2024 in the Official Gazette. The incentives include the
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Panama introduced procedure to allow transfer of tax credits
Panama’s tax administration (Dirección General de Ingresos, DGI) introduced a procedure that allows taxpayers to transfer tax credits from income tax, property tax, education insurance tax, complementary tax, and dividend tax to another
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UN publishes draft guidance on carbon offsets, carbon credits in transfer pricing
The UN Subcommittee on Transfer Pricing published an advanced unedited version of the guidance Interstitial Guidance on Transfer Pricing of Carbon Offsets and Carbon Credits on 28 August 2024. The draft is an updated version of a document
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Lithuania moves towards full implementation of Pillar Two global minimum tax
Seimas, the Lithuanian parliament is reviewing a draft law to fully implement the Pillar Two global minimum tax, in line with Council Directive (EU) 2022/2523 of 14 December 2022. According to the draft, the law for full implementation is set to
See MoreOECD: Latest Edition of Tax Policy Reforms
On 30 September 2024 the OECD published the latest edition of Tax Policy Reforms: OECD and Selected Partner Economies. This annual publication provides comparative information on tax reforms in a number of countries. The latest report looks at the
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El Salvador passes tax incentives for major real estate projects
El Salvador’s Congress (Legislative Assembly of El Salvador) approved a decree titled “Special Provisions for the Promotion and Granting of Tax Incentives to Foster the Development of High-Rise Real Estate Projects” on 23 September
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