US: IRS and Treasury to hold hearing on dual consolidated loss rules, disregarded payments treatment
The US Internal Revenue Service (IRS) and Treasury announced a public hearing regarding the proposed Rules on Dual Consolidated Losses and Certain Disregarded Payments on 11 November 2024. This document provides a notice of public hearing on the
See More
Luxembourg revises draft law to amend Pillar Two global minimum taxation
The Luxembourg government published a revised draft law on 31 October 2024 amending the Global Minimum Taxation Law, commonly referred to as the Pillar Two law. This revised draft introduces additional amendments to the initial draft published on
See More
Ireland: Lower House of Parliament passes Finance Bill 2024
The Irish lower house of parliament approved the Finance Bill 2024, which outlines major tax measures from Budget 2025 on Wednesday, 5 November 2024. Finance Bill 2024, which runs to 118 sections and over 200 pages, implements the taxation as
See More
Hungary announces reporting obligations for taxpayers under global minimum tax
Hungary announced the autumn tax package proposal on 29 October 2024, which includes the reporting obligations for taxpayers under the Global Minimum Tax Act. The latest proposal has no amendments compared to the previous version released for public
See More
Indonesia extends tax holiday for key industries, adapts global minimum tax
Indonesia has issued Regulation No. 69 of 2024, extending the tax holiday incentives for pioneer industries as outlined in Regulation No. 130/PMK.010/2020. Regulation No. 130/PMK.010/2020 replaces Regulation No. 150/PMK.010/2018 and extends
See More
Ireland approves new global tax reform rules
Ireland's parliament has passed a bill simplifying transfer pricing for marketing and distribution and amending global minimum tax rules on 6 November 2024. This legislation was enacted as part of the Finance Bill 2024, which was approved by both
See More
Kenya proposes new economic presence and minimum top-up taxes in Tax Laws Bill 2024
Kenya's National Assembly presented the Tax Laws (Amendment) Bill 2024 along with the Tax Procedures (Amendment) (No.2) Bill 2024 on 1 November 2024. Both Tax Laws (Amendment) Bill 2024 along with the Tax Procedures (Amendment) (No.2) Bill 2024
See More
Slovak Republic issues guidance on reintroduced minimum tax
The Slovak Republic Financial Administration released Document No. 13/PO/2024/IM, offering guidance on paying minimum tax or tax licences on 28 October 2024. The Slovak Republic has reinstated the obligation for companies to pay a minimum tax
See More
Netherlands clarifies minimum tax to have little effect on incentives, cautions on new tax credits
The Netherlands State Secretary for Finance, in a letter to the parliament, stated that the global minimum tax would have limited effects on current tax incentives but highlighted that the newly introduced tax credits under Pillar Two could pose
See More
Hungary to amend local and EU tax laws, achieve social and policy objectives
Hungary’s government concluded a public consultation on a draft bill proposing changes to various tax laws on 24 October 2024. The proposal seeks to amend tax laws in response to EU and Hungarian legislation changes, targeting global minimum tax,
See More
Austria: Appointment of alternative Pillar Two taxpayer due by December
The appointment of an alternative Pillar Two taxpayer in Austria, for taxpayers operating on a calendar year basis, is required to be submitted to the relevant tax office by 31 December 2024. Evidence of this appointment must be uploaded to
See More
Italy gazettes decree on Pillar Two substance-based income exclusion
Italy published the Decree of 11 October 2024 in the Official Gazette on 23 October 2024, which addresses reducing the taxable base relevant to the global minimum tax. Earlier, Italy’s Ministry of Economy and Finance announced the Decree of 11
See More
US: Treasury, IRS relieves tax-exempt organisations from CAMT form filing for 2023 tax year
The US Department of Treasury and the Internal Revenue Service (IRS), in a release – IR-2024-277, granted a filing exception for tax-exempt organisations on 23 October 2024; they do not have to file Form 4626, Alternative Minimum Tax –
See More
Belgium consults Pillar Two supplementary tax form
Belgium's Federal Public Service (SPF) Finance has launched a consultation on the proposed annual supplementary national tax return form. The supplementary national tax applies to in-scope groups starting their tax years on or after 31 December
See More
Italy implements decree on Pillar Two substance-based income exclusion
Italy's Ministry of Economy and Finance announced that the Decree of 11 October 2024, which provides implementation rules on the substance-based income exclusion (SBIE) to be applied when calculating the due amount of top-up tax and is being
See More
Poland to introduce cash grants amid potential impact of Pillar Two on investment zone incentives
Poland's Ministry of Development and Technology (MRiT) announced plans to reform the country's incentives system by introducing cash grants linked to investment profitability. The cash grant incentive regime aims to maintain Poland's
See More
Slovak Republic presents draft bill to amend Pillar Two rules
The Slovak Republic’s government presented a draft bill to the Parliament, on 11 September 2024, to amend the Pillar Two global minimum tax rules enacted on 8 December 2023. The proposed amendments cover financial accounting standards for
See More
Brazil consults Qualified Domestic Minimum Top-Up Tax
Brazil’s Federal Revenue Service has initiated a public consultation regarding the additional social contribution to net profits (Contribuição Social Para o Lucro Líquido, CSLL). The consultation will be open from 4 October to 10 November,
See More