CJEU Advocate General supports Luxembourg’s ATAD transposition on securitisation entities from interest limitation rules
The Advocate General (AG) Juliane Kokott of the Court of Justice of the European Union (CJEU) has issued her opinion in Case C-138/24, involving an infringement claim by the European Commission against the Grand Duchy of Luxembourg on 18 June
See MoreIndia expands tax exemptions for foreign investors in government securities
India has published the Income-Tax (Amendment) Commencement Ordinance 2026 in the Official Gazette on 5 June 2026, introducing a targeted set of tax reforms aimed at strengthening foreign participation in Indian Government securities markets. The
See MoreCyprus: Tax Department announces new payment method for defence, health contributions
The Cyprus Tax Department announced, on 26 March 2026, the introduction of a temporary change in how certain contributions are paid for the 2026 tax year. For the time being, taxpayers will make payments for the following contributions directly
See MoreBelgium: Parliament passes tax bill on withholding refunds, bank taxes
Belgium’s parliament passed legislation on 18 December 2025, proposed by multiple Members of Parliament, to introduce changes to the refund of withholding tax and to raise the tax on credit institutions. The legislation aims to update the 1992
See MoreNigeria mandates withholding tax on interest from short-term securities
FIRS announced that interest from short-term securities investments will now be subject to withholding tax. Nigeria’s Federal Inland Revenue Service (FIRS) issued a public notice on 17 September 2025, mandating withholding of tax on interest
See MoreKazakhstan consults on liquidity criteria for tax exempt securities
The consultation ends on 14 August 2025. Kazakhstan launched a public consultation on liquidity criteria for securities traded on its stock exchanges on 30 July 2025. These criteria will determine eligibility for a tax exemption on dividends
See MorePhilippines: DoF clarifies 20% final tax on interest income is not a new levy under Capital Markets Act
The DoF clarified that the 20% final tax on interest income standardises rates to address inequities favouring the wealthy, rather than introducing a new tax. The Philippines Department of Finance (DoF) released a statement on 17 July 2025 to
See MoreBrazil: Government to raise tax on interest on equity in fiscal package
Brazil's Finance Ministry plans to increase the income tax on interest on equity (JCP) payments from 15% to 20% as part of a new fiscal package. Brazil's Finance Minister, Fernando Haddad, announced on 10 June 2025 that the government is
See MorePhilippines enacts Capital Markets Efficiency Promotion Act (CMEPA)Â
Philippine President Ferdinand R. Marcos, Jr. has signed the Capital Markets Efficiency Promotion Act (CMEPA) into law on 30 May 2025, which goes into force on 1 July 2025. Philippine President Ferdinand R. Marcos, Jr., has signed the Capital
See MoreNew Zealand lowers interest rates on tax underpayments and overpayments
New Zealand Inland Revenue updated the UOMI Rates on 28 May 2025. Underpayment rates drop to 9.89% (from 10.88%), and overpayment rates decrease to 3.27% (from 4.30%). The New Zealand Inland Revenue has published the revised Taxation (Use of
See MoreCyprus 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
See MoreUS: IRS updates guidance on branch-level interest tax
The US Internal Revenue Service (IRS) has released an updated practice unit on Branch-Level Interest Tax Concepts. Below is a general overview of the key points covered in this publication: Note: This Practice Unit was updated to remove
See MoreBosnia and Herzegovina: Republika Srpska Assembly extends deadline to write off interest on unpaid public revenuesÂ
The National Assembly of the Republic of Srpska, Bosnia and Herzegovina, extended the deadline for writing off default interest on unpaid public revenues on 26 March 2025. The new deadline to pay outstanding liabilities and claim the write-off is
See MoreHong Kong cuts tax reserve certificate interest rates
Hong Kong’s Inland Revenue Department announced, on 28 January 2025, that starting from 3 February 2025 the new annual rate of interest payable on Tax Reserve Certificates will be 0.3417% against the current rate of 0.4250%, i.e. the new rate will
See MoreHong Kong updates tax-exempt debt instruments list
The Hong Kong Inland Revenue Department (IRD) has released the latest updated lists of Qualifying Debt Instruments (QDIs) as at the end of 30 September 2024 on 2 December 2024. The lists include: Qualifying Debt Instruments issued before 1
See MoreHong Kong cuts tax reserve certificate interest rate
The Hong Kong Inland Revenue Department, on Friday, 31 May, 2024, announced a change in the rate of interest payable on Tax Reserve Certificates in a legal notice published in the Government Gazette. The notice includes a reduction in the annual
See MoreNew 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
See MoreHong 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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