South Africa revises guide for withholding tax on royalties return
SARS updates guide for Withholding Tax on Royalties (WTR01), effective 30 May 2025. Includes filing, payment, and refund processes, with references to the Income Tax Act. Email submissions remain open for LBI and HWI taxpayers. The South African
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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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US: 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
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Bosnia 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
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Namibia announces tax proposals in 2025-26 budgetÂ
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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Hong 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
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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 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
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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
See MoreUS: 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 changesÂ
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 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
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Australia: Queensland proposes law to prevent coal royalty rate cuts without legislative approval
Australia’s Queensland government proposed the Progressive Coal Royalties Protection (Keep Them in the Bank) Bill 2024 to the state Parliament on 23 May, 2024. This legislation aims to amend the Mineral Resources Act 1989 by ensuring that coal
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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