Netherlands updates tax penalty rules
The Netherlands State Secretary for Finance has published Decree No. 2024-15074 of 18 December 2024 in the Official Gazette on 31 December 2024, outlining various tax penalties which include several penalty increases effective from 1 January
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Germany: Federal Council approves revised Bill for tax law advancements, income tax adjustments
The German Federal Council (Bundesrat) approved the updated version of the bill aimed at further developing tax law and adjusting the income tax brackets on 20 December 2024. It will enter into force after publication in the Official Gazette. The
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Russia: MoF clarifies loss carry-forward rules for CFCs redomiciled as international companies
The Russian Ministry of Finance (MoF) clarified in Guidance Letter No. 03-12-11/2/107192, published on 9 December 2024 that, under certain conditions, losses can be carried forward by a controlled foreign company (CFC) registered in Russia and
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Thailand introduces Pillar Two top-up tax for MNEs
Thailand's Revenue Department has announced the publication of the Emergency Decree on Top-up Tax B.E. 2567 (2024) in the Official Gazette on 26 December 2024,introducing the implementation of a domestic minimum top-up tax for MNE groups with a
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Singapore: IRAS publishes new guidance on MNE top-up tax, domestic top-up tax
The Inland Revenue Authority of Singapore (IRAS) has released a new e-Tax Guide on the Multinational Enterprise (MNE) Top-up Tax (MTT) and Domestic Top-up Tax (DTT) on 31 December 2024. This e-Tax guide sets out the key parameters of the MTT and
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Oman introduces Domestic Minimum Top-Up Tax for MNEs
The Oman Tax Authority has confirmed that a Royal Decree has been issued which implements a domestic minimum top-up tax, with a minimum effective tax rate of 15%, for multinational enterprise (MNE) groups in Oman, provided that these groups
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Kuwait introduces supplementary domestic minimum top-up tax for MNEs
Kuwait's Ministry of Finance announced on X that a supplementary domestic minimum top-up tax (DMTT) for large multinational enterprises (MNEs) has been introduced through Decree No. (157) of 2024 on 30 December 2024. The Decree is designed to
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Italy issues decree on Pillar Two rules, deferred tax attributes on transition
Italy’s Ministry of Economy and Finance has published the Ministerial Decree of 20 December 2024 in Official Gazette No. 304 of 30 December 2024. The Decree outlines additional implementation rules for the top-up tax introduced under Legislative
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Russia introduces reduced corporate income tax rate for electronics manufacturers
Russian companies manufacturing equipment for electronic components and radio-electronic products will benefit from a reduced 8% corporate income tax rate starting 1 January 2025. This tax incentive is part of government Resolution No. 1848,
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Luxembourg enacts bill amending global minimum taxation law
Luxembourg has enacted the bill amending the law that implements the Minimum Taxation Directive (2022/2523) on 23 December 2024, known as the Minimum Taxation Law of 22 December 2023 (MTL), incorporating guidance and clarifications from the OECD’s
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Brazil enacts Pillar Two global minimum tax rules
The President of Brazil, Luiz Inácio Lula da Silva, enacted Bill No. 3,817/24, which is now known as Law No. 15,079/24, implementing the OECD's Pillar Two global minimum tax and introduces the global anti-base erosion (GloBE) regulations within
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Turkey introduces 1% withholding tax on e-commerce intermediary payments
Turkey's Revenue Administration has announced the issuance of Presidential Decision No. 9284, introducing a 1% withholding tax rate on payments made by intermediaries to service providers engaged in activities under Law No. 6563 on the Regulation of
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Qatar: Parliament approves introduction of Pillar Two global minimum tax
Qatar's General Tax Authority has announced that the Shura Council (parliament) has approved amendments to implement measures for the Pillar Two global minimum tax. During its regular weekly session convened on 23 December 2024 at the Council’s
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Australia: ATO consults implementation of thin capitalisation third-party debt test
The Australian Taxation Office (ATO) has initiated a public consultation regarding the implementation of the thin capitalisation third-party debt test . Additionally, it addresses the associated Schedule 3 of Draft Practical Compliance Guideline
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US: Treasury Department, IRS publish final regulations on the treatment of tax-exempt bonds as retired
The US Treasury Department and IRS released final regulations (T.D. 10020) regarding when tax-exempt bonds are treated as retired on 27 December 2024. The final regulations address when tax-exempt bonds are treated as retired for certain Federal
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Australia to amend law to strengthen tax penalty regime
Australia’s government will be amending the tax law to strengthen the current tax penalty regime, as part of the 2024–25 Mid-Year Economic Fiscal Outlook. The announcement was made by ATO is a release on 18 December 2024. The new measure
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Poland updates Corporate Income Tax Haven List
The Polish Official Gazette published Regulation No. 1928 on 24 December 2024, updating the list of tax havens for corporate income tax. The regulation enters into force 1 January 2025 The provisions apply to transfer pricing documentation
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Hong Kong gazettes amendment to Minimum Tax for Multinational Enterprise Groups Bill 2024
Hong Kong announced that the Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Bill 2024 was published in the Gazette on 27 December. The Bill seeks to implement the international tax reform framework, Base Erosion and
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