OECD releases latest Pillar Two compliance insights
The OECD has released essential guidance on implementing the Pillar 2 GloBE rules on 15 January 2025. Jurisdictions implementing Pillar 2 must calculate an MNE’s tax liability using their local legislation, which may differ from calculations
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UK: HMRC reduces interest rates for late payments, overpayments
The UK's tax authority, His Majesty's Revenue and Customs (HMRC), has announced a reduction in interest rates for late payments and overpayments of taxes: The new rates are 7% for late payments and 3.5% for overpayments. This development follows
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Ireland: Revenue publishes eBrief No. 014/25 on surcharge for undistributed income of close companies
Irish Revenue has published eBrief No. 014/25 20 January 2024, providing updated guidance on the surcharge for certain undistributed income of close companies, Tax and Duty Manual Part 13-02-05. Section 440 TCA 1997 provides for an additional
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Lithuania raises dividend tax rate from January 2025
Lithuania’s State Tax Inspectorate (STI) has introduced new guidelines on the increase of the dividend tax rate from 15% to 16%, effective from 1 January 2025. A dividend tax is levied by a jurisdiction on dividends paid by a corporation to its
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Colombia: Tax Authority clarifies tax losses and exempt dividends under CHC regime
Colombia's tax authority issued Official Tax Opinion No. 100208192-69 on 17 January 2025, providing clarification on the treatment of tax losses and corporate income tax-exempt dividends under the Colombian holding company (CHC) regime. An
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Ireland: Revenue updates CFC rules in eBrief 023/25
The Irish Revenue released eBrief 023/25 on 24 January 2025, which includes updates to the tax and duty manual on Controlled Foreign Company (CFC) rules, in light of the changes introduced by the Finance Act 2024. Tax and Duty Manual - Part
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Netherlands clarifies tax impact of asset transfers in fiscal unity liquidation
The Netherlands Ministry of Finance has issued Notification No. 2024-0000030104 on 5 February 2025, addressing the tax implications of asset transfers during the liquidation of a company within a fiscal unity. Under the Article 15ai of the
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Slovak Republic considers reinstating tax exemption on capital gains on private sharesÂ
The Slovak Republic government has approved Update No. 3 of the Action Plan for the National Strategy on Research, Development, and Innovation on 3 February 2025. This update also includes tax measures and is a part of the government Resolution
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El Salvador amends VAT and withholding tax returns
El Salvador’s Ministry of Finance has introduced new fields to Form 07 and Form 14, which taxpayers will be required to complete starting 1 February 2025. The forms have been updated to include the following changes: Sales to taxpayers;
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Italy releases jurisdictions with transitional qualified status for Pillar Two
Italy’s Ministry of Economy and Finance has released a document listing jurisdictions with transitional qualified status for implementing the domestic minimum top-up tax (DMTT) and income inclusion rule (IIR). The list also shows which DMTTs
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UK: HMRC amends Pillar Two rules
The UK tax authority, His Majesty’s Revenue and Customs (HMRC), published amendments to the Finance Bill 2024-2025 on 27 January 2025, introducing changes to the UK’s Pillar Two regulations. The bill includes modifications to the Undertaxed
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US: FinCEN updates beneficial ownership information reporting rules
The US Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an update on beneficial ownership information (BOI) reporting requirements on its BOI webpage. The alert states that the Justice Department, on behalf of the
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OECD consults Tax Incentives Principles
The Platform for Collaboration on Tax (PCT), under the Organisation for Economic Co-operation and Development (OECD), has initiated a public consultation draft titled “Tax Incentives Principles” on 10 December 2024. The consultation draft seeks
See MoreIMF: Revenue and Spending Measures for Developing Countries to Reduce Debt Levels
An IMF Public Finance Management (PFM) Blog, written by Talal Rafi (a Director at EY Sri Lanka) and published on 27 January 2025, looked at the measures developing countries can take to reduce public debt levels. The author notes that more than 3
See MoreIMF Report Makes Tax Policy Recommendations for Japan
On 7 February 2025 the IMF published a report following discussions with Japan under Article IV of the IMF’s articles of agreement. The report notes that Japan’s economy contracted in the first half of 2024 as a result of temporary supply
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South Africa: SARS updates interest rate for taxation of low-interest loans
The South African Revenue Service (SARS) has announced a reduction in the official interest rate Table 3 for taxation on interest-free or low-interest loans, lowering it from 8.75% to 8.50%, effective 1 February, 2025. This change follows a
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Ecuador adjusts withholding rates for large taxpayers’ self-withholding obligation
Ecuador's Internal Revenue Service (SRI) issued Resolution No. NAC-DGERCGC25-00000003 of 31 January 2025, updating withholding tax rates for "large taxpayers." The SRI defines companies as “large taxpayers”. The self-withholding obligation
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Chile clarifies CFC rules, updates preferential tax jurisdictions
Chile’s tax administration published Circular Letter 11/2025 on 30 January 2025, which introduced Law 21.713, regarding controlled foreign company (CFC) regulations, preferential tax regimes, and the indirect sale of assets in Chile. The Law
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