Netherlands: Tax Administration clarifies domestic withholding exemption may apply to outbound dividends despite treaty ineligibility
The Tax Administration has clarified its position on whether dividends can qualify for a withholding tax exemption under Article 4(2) of the Dividend Withholding Tax Act if they don’t qualify for treaty benefits. The Dutch Tax Administration
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Cyprus imposes new defensive tax rules on payments to low-tax and non-cooperative jurisdictions
Cyprus has published Laws No. 47(I)/2025 and No. 48(I)/2025 in the Official Gazette on 16 April 2025. These laws introduce updated defensive measures on outbound payments of dividends, interest, and royalties to non-cooperative or low-tax
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Belgium: Government presents tax reform plan to parliament, includes VAT measures
The Belgian Chamber of Representatives has released a policy note on 24 April 2025 detailing its tax reform plans for the upcoming year. The key measures of the tax reform plan include: Dividends received deduction rules Enhancing the
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Namibia announces tax proposals in 2025-26 budget
Namibia’s Ministry of Finance unveiled the 2025-26 budget on 27 March 2025, outlining several tax proposals, including corporate tax reductions, VAT changes, and higher excise duties. Namibia’s national budget has risen to NAD 106.3 billion,
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Israel: Knesset passes trapped profits law
Israel’s Knesset has passed the Trapped Profits Law (tax on excess undistributed profits) on 29 December 2024. The law imposes a 2% tax on excess undistributed profits of closely held holding companies (entities with five or fewer
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Romania raises dividend tax, updates micro-enterprise rules
Romania has issued Emergency Ordinance no. 156 of 30 December 2024, which introduces various amendments to the Tax Code (Law no. 227/2015), which took effect on 1 January 2025. One significant change includes raising the dividend tax rate from 8%
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Hong Kong publishes advance tax ruling on in-kind dividend in restructuring
The Hong Kong Inland Revenue Department (IRD) has released Advance Ruling Case No. 75 on 30 September 2024, addressing the tax implications of an in-kind dividend involved in a restructuring. Advance Ruling Case No. 75 1. The provisions of the
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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
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US: IRS clarifies CFC not eligible for dividends received deduction under section 245A
The US Internal Revenue Service (IRS) issued an Office of Chief Counsel memorandum clarifying that a controlled foreign corporation (CFC) is not eligible for a dividends received deduction under section 245A. This memorandum provides
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Malaysia: 2025 budget unveils dividend tax, new tax incentives, sales and service tax changes
Malaysia announced its 2025 Budget on 18 October 2024 with various tax measures. Dividend tax Starting from the year of assessment 2025, a 2% dividend tax will be applied to the annual chargeable dividend income of individuals exceeding MYR
See MoreUS: IRS extends transitional relief for certain dividend equivalent rules
The US Internal Revenue Service (IRS) has declared that the Treasury and IRS plan to amend section 871(m) regulations, as stated in Notice 2024-44. This amendment will postpone the effective and applicability dates of specific provisions. This
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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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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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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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