Ireland: Revenue revises guidance on Interest Limitation Rule
Irish Revenue has published eBrief No. 292/24 updated guidance on the Interest Limitation Rule on 29 November 2024. This includes revisions to sections 8 and 9 of the guidance, reflecting changes introduced by the Finance Act 2024. In sections 8
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Ukraine raises tax on banks, financial institutions
Ukraine has signed Law 4015-IX (The Law on Amendments to the Tax Code of Ukraine and Other Laws of Ukraine to Ensure the Balance of Budget Revenues during Martial Law) into law on 28 November 2024. One key provision of this new law is the increased
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India scraps windfall tax on fuel and crude oil domestic production, exports
India's Central Board of Indirect Tax and Customs (CBITC) has issued Notification 29/2024 on 2 December 2024, which repeals the previous directives related to implementing the Special Additional Excise Duty (windfall tax) on the domestic production
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Qatar: Council of Ministers approve Pillar Two global minimum tax
Qatar's Council of Ministers approved the proposed amendments to the Income Tax Law, on 4 December 2024, for the implementation of measures aligned with the Pillar Two global minimum tax framework. As part of the inclusive framework on Base
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US: Treasury, IRS finalise rules on tax credit for clean energy investments
The US Department of the Treasury and Internal Revenue Service (IRS) have released the final rules for the Section 48 Energy Credit – also known as the Investment Tax Credit (ITC), on 4 December 2024. The rules were scheduled to be published in
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Hungary scraps several windfall taxes on profits, adjusts and extends others
Hungary issued the Government Decree 356/2024 in the Official Gazette on 21 November 2024, amending Government Decree 197/2022 on temporary windfall taxes on additional profits. The Decree also scraps some windfall taxes while modifies and extends
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Slovenia gazettes amendments to Corporate Income Tax Law
Slovenia published amendments to the Corporate Income Tax Act (ZDDPO-2U) in the Official Gazette on 26 November 2024. The changes, applicable to tax periods starting 1 January 2025, introduce new rules for corporate taxation. Tax loss
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South Africa: SARS clarifies tax allowances, deductions for renewable energy generation assets
The South African Revenue Service (SARS) has released a guide “Guideline on the on Allowances and Deductions Relating to Assets Used in Generation of Electricity from Specified Sources of Renewable Energy” on 23 November 2024. It provides
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US: IRS and Treasury extend consultation deadline for proposed CAMT regulations
The US Treasury Department and Internal Revenue Service (IRS) have announced an extension for submitting comments on the proposed regulations (REG-112129-23) concerning corporate alternative minimum tax (CAMT) on 4 December 2024. Initially published
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Turkey reduces tax exemption on long term capital gains
The Revenue Administration of Turkey has announced the decision (Presidential Decision No. 9160) to reduce the tax exemption on capital gains from the sale of participation shares, held for at least two years, from 75% to 50%. This adjustment
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Ireland clarifies interest deductions for connected party loans
Irish Revenue has published a new Tax and Duty Manual – Part 36-00-19 Interest on loans to defray money applied for certain purposes 27 November 2024, providing guidance on section 840A TCA 1997. Section 840A is an anti-avoidance provision
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Switzerland: Federal Council recommends rejecting loss carryforward time limit extension
The Swiss Federal Council announced the adoption of a dispatch proposing legislation to extend the loss carry forward period from seven years to 10 years on 27 November 2024. The draft law responded to a motion submitted by Parliament, motivated by
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Taiwan: Ministry of Finance announces withholding tax system optimisations, effective 1 January 2025
To optimise Taiwan’s income tax withholding system and protect the rights and interests of taxpayers, amendments to the Income Tax Act, announced on 7 August 2024, will be promulgated on 1 January 2025, as approved by the Executive Yuan. The
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Hong Kong consults tax breaks for asset, wealth management
The Hong Kong SAR (HKSAR) government released a consultation paper to selected stakeholders, seeking their feedback on proposed improvements to the preferential tax regimes. These enhancements focus on funds, family-owned investment holding vehicles
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Singapore enacts Multinational Enterprise (Minimum Tax) Act, Income Tax (Amendment) Act
Singapore has enacted two tax laws, Income Tax (Amendment) Act 2024 and Multinational Enterprise (Minimum Tax) Act 2024, with the aim to align with global tax standards, enhance business competitiveness, and introduce targeted incentives for
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US: IRS and Treasury propose rules on taxed earnings, basis adjustments
The US Internal Revenue Service (IRS) and Treasury Department have issued proposed regulations (REG-105479-18) on 2 December 2024, addressing previously taxed earnings and profits (PTEP) of foreign corporations and the associated basis
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Angola proposes new tax compliance, registration rules in 2025 budget
Angola’s government had submitted the 2025 State Budget Law on 31 October 2024 with various tax measures. The proposed tax measures state that: Non-compliant taxpayers will still face restrictions on financial transactions and work permit
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Argentina scraps advance PAIS tax on imports
Argentina’s tax authority (ARCA) has announced that it eliminated the 95% advance payments of the PAIS tax (Impuesto Para una Argentina Inclusiva y Solidaria) on foreign currency purchases for imports, effective 25 November 2024. This is
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