New Zealand issues 2024 international tax disclosure exemption
On 3 April 2024, the New Zealand Inland Revenue published a determination concerning the 2024 international tax disclosure exemption. This eases the obligation of taxpayers to report their interests in foreign entities for the income year that
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Ireland: Irish Revenue publishes guidance on outbound payment measures
On 25 March 2024, the Irish Revenue released eBrief No. 096/24 outlining new guidance on Outbound payments defensive measures. This latest guidance has been issued as part of the Finance (No.2) Act 2023. The Finance (No.2) Act 2023 inserted Chapter
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Germany introduces stricter reporting requirements for listed companies under new tax relief Act
The Federal Central Tax Office (BZSt) has released a communication manual outlining the requirements of the German Withholding Tax Relief Modernization Act. This act mandates that listed companies in Germany report shareholder information to the
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New Zealand proposes multiple amendments for taxation bill
On March 14, 2024, the New Zealand Inland Revenue released Amendment Paper No. 20 outlining proposed amendments to the Taxation (Annual Rates for 2023–24, Multinational Tax, and Remedial Matters) Bill. The proposed changes are as follows:
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India: CBDT passes finance act 2024 with limited tax provisions
The Central Board of Direct Taxes (CBDT) in India has released the Finance Act 2024, passed on 15 February 2024, to execute the provisions of the Union Budget for 2024-2025. The finance Act includes the following key tax measures: The criteria
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Hong Kong revises eligible debt instruments for profits tax concessions
On 6 February 2024, the Hong Kong Inland Revenue Department (IRD) released the updated lists of Qualifying Debt Instruments (QDIs) at the end of 31 December 2023. The lists include: Qualifying Debt Instruments issued before 1 April 2018
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Malaysia releases practice note on tax treatment of copyright and software payments to non-residents
On 5 December 2023, the Inland Revenue Board of Malaysia (IRBM) announced Practice Note No. 3/2023, in which it clarified the Tax treatment of copyright and software payments made by distributors and resellers to non-residents. In general,
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Germany: MOF issues draft guidance on anti-tax avoidance measures
On 30 November 2023, the German Ministry of Finance (MoF) issued draft guidance on anti-tax avoidance measures targeting non-cooperative jurisdictions. This follows the 2021 Tax Haven Defense Act, responding to EU guidelines against harmful tax
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Bulgaria officially approves budget Act 2023
Bulgaria has passed the amendments to the draft Budget Act 2023, which aim to protect wages and social security benefits. The government plans to reduce spending to combat inflation and strengthen the economy, but will not raise taxes. The key tax
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Egypt publishes income tax amendment law
On 15 June 2023, the Egyptian Tax Authority published Law No. 30 of 2023 in the Official Gazette amending some provisions of the Income Tax Law No. 91 of 2005. The Law entered into force on 16 June 2023. The key amendments to the Income Tax Law are
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Peru shifts from LIBOR to SOFR for lower withholding tax on nonresident interest
On 29 June 2023, Peru published Supreme Decree 137-2023 in the Official Gazette for the adoption of the Secured Overnight Financing Rate (SOFR) to replace the London Interbank Offered Rate (LIBOR). The Decree came into force on 30 June 2023. This
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India: Finance bill 2023 passed in the lower house of Parliament
On 24 March 2023, the lower house of Parliament (Lok Sabha) passed the Finance Bill 2023 which implements tax proposals for the next fiscal year. The Bill received 64 official amendment proposals, among which one intends to remove extended tax
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France issues ruling on withholding tax applicable to dividend equivalent payments
On 24 February 2023, the French tax authority released two rulings related to the levy of dividend withholding tax on payments to non-residents for financial transactions that are deemed to be equivalent to dividends. In the first ruling, it is
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New Zealand: Finance and Expenditure Committee proposes additional measures to the taxation bill
On 2 March 2023, the Finance and Expenditure Select Committee submitted a report to Parliament on the Taxation (Annual Rates for 2022–23, Platform Economy, and Remedial Matters) Bill (No 2), introduced on 8 September 2022. The committee has
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Sri Lanka: IRD clarifies amendment to dividend taxation
20 January 2023, the Sri Lankan Inland Revenue Department (IRD) published a notice regarding changes in the taxation of dividends. As the National Budget of 2023 presented and passed in Parliament, following proposals specified under item No.1.3 of
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Belarus issues law on various tax amendment
On 4 January 2023, Belarus published Law No. 230-Z in the Official Gazette amending various tax measures. The following are the key amendments to the tax code: From 1 January 2023, the deadline for submitting transfer pricing documentation to
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France publishes interest rate limits for shareholder loan
France has published interest rates for entities whose financial year (FY) ended between 31 December 2022 and 30 March 2023, which are used to determine the deductibility of interest payments to shareholders. If the interest payments exceed the
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Ireland updates guidance on payment and receipt of interest and royalties without deduction of income tax
On 22 December 2022, the Irish Revenue published eBrief No. 221/22 on payment and receipt of interest and royalties without deduction of income tax. Accordingly, Tax and Duty Manual Part 08-03-06 - Payment and Receipt of Interest and Royalties
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