World Tax Brief: January 2024
Belgium International-CFC: The government proposes stricter rules on taxing undistributed income of controlled foreign companies, shifting from anti-avoidance to targeting passive income in the EU Anti-Tax Avoidance Directive. Double taxation
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Philippines: BIR clarifies withholding tax made by online payment platforms
On 15 January 2024, the Philippines Bureau of Internal Revenue (BIR) published the Revenue Memorandum Circular No. 8-2024 of 15 January 2023, in which it clarified the imposition of the new 1% withholding tax for payments by online platforms to
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Norway enacts global minimum tax pillar 2 and amends tax administration act and tax payment act
On 12 January 2024, Normay announced the Supplementary Tax Act in the Official Gazette, which provides the provisions for implementing the Pillar 2 global minimum tax. This includes the introduction of the Pillar 2 income inclusion rule (IIR) to
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Venezuela approves extension of temporary VAT exemptions on hydrocarbon fuels
On 12 January 2024, Venezuela published Decree No. 4.911 in Official Gazette No. 42.797. This decree extends the temporary exemption on VAT, customs duty, and related taxes for the import and sale of hydrocarbon fuels and additives that improves
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Zambia enacts tax amendments outlined in the budget 2024
On 22 December 2023, Zambia took a significant step in reshaping its fiscal landscape by enacting various amendment acts to implement the 2024 budget tax changes. The key highlights of these tax measures include: Income Tax Adjustments:
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South Africa releases 2023 tax Acts with significant amendments
On 22 December 2023, the South African Revenue Service officially published the 2023 tax acts, marking a substantial reform in the country's fiscal landscape. The key acts include the Taxation Laws Amendment Act, 2023 (Act 17 of 2023), the Tax
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Italy announces new deadline for transfer pricing documentation
On 12 January 2024, Italy published the Legislative Decree no. 1/2024 in the Official Gazette. The Decree details the simplification and rationalization of certain tax rules, including introducing a new tax calendar. From 2 May 2024, taxpayers
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Ukraine introduces CbC reports filing for the first time
On 11 January 2024, the State Tax Service of Ukraine, in a release announced it has introduced Country-by-Country (CbC) reporting for the parent companies of the international groups of companies for the first time in the country. The CbC reporting
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Belgium: Constitutional court revokes several federal and regional DAC6 legislation
On January 11, 2024, the Belgian Constitutional Court released a statement regarding four judgments related to legislation passed by the Federal government, the Walloon region, Brussels, and the French Community. These judgments pertain to the
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Kazakhstan broadens special retail tax regime qualifying activities
On 12 January 2024, Kazakhstan's State Revenue Committee released the Government Decree No. 1240 of 29 December 2023. The Government Decree came into effect on 15 January 2024. This Decree of the government outlines the types of activities for
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Argentina: National congress mulls new Incentive regime for major investments
The Argentine National Congress is evaluating a draft legislation to establish a new incentive regime for major investments by sole purpose vehicles in specific sectors. The sole purpose vehicles for the new incentive regime include corporations,
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Spain approves extension of windfall taxes on banks and reduced VAT rates
On 11 January 2024, the Spanish Government issued a press release announcing the approval of the Royal Decree-Law. The Royal Decree-Law was approved by the Spanish Council of Ministers on 27 December 2023. This Decree extends specific measures to
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Transfer Pricing Brief: January 2024
Algeria Transfer pricing information return: Algeria published the Supplementary Finance Law for 2023 in the Official Gazette. A new transfer pricing declaration obligation has been introduced, requiring taxpayers to submit an online transfer
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Saudi Arabia: ZATCA extends tax penalty relief measures until 30 June 2024
On 29 December 2023, Saudi Arabi’s Zakat, Tax and Customs Authority (ZATCA) announced the extension of the "Cancellation of Fines and Exemption of Penalties initiative until 30 June 2024. ZATCA stated that the initiative's extension, which ends
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Albanian official Gazette publishes revised AEOI jurisdictions list
On 5 January 2024, Albania's Official Gazette announced Decision No. 817, a major update to its automatic exchange of financial account information (AEOI) program. This decision revamps the lists of participating and reportable jurisdictions,
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India: CBDT issues guidelines for withholding tax on e-commerce transactions
On 28 December 2023, the Central Board of Direct Taxes (CBDT) issued guidelines clarifying the deduction of withholding tax in e-commerce transactions under Section 194-O of the Income-tax Act, 1961. The details of the guidelines are outlined as
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Luxembourg publishes municipal rate multipliers for 2024
On 9 January 2024, the Luxembourg Administration of Direct Tax (Administration des Contributions Directes) released a newsletter regarding the municipal rate multipliers (coefficients) for the 2024 tax year. These coefficients were initially
See MoreBelgium approves 2024 budget Introducing new CFC rules
Belgium has approved the 2024 budgetary measures, including new CFC rules, increased progressive tax on credit institutions, and strengthening Cayman tax rules. New CFC rules One key aspect of Belgiam’s CFC rules is the implementation of the
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