Hungary offers tax amnesty for previously ineligible shares
Recently, Hungary implemented a tax legislation that grants one-time amnesty for any capital gains on the disposal of shares in subsidiaries that had not previously chosen to participate in Hungary's capital gains exemption regime. Hungary’s
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Russia: CBR increases the interest rates to 16%
On 15 December 2023, the Russian Central Bank (CBR) announced the decision to increase the key rate from 15% to 16% in an effort to combat rapidly rising inflation. The Central Bank of Russia utilizes its key interest rate to determine interest
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Austria: Nationalrat approves bill to implement Pillar 2 global minimum tax
On 14 December 2023, the Austrian lower house of parliament (Nationalrat) approved Bill No. 2322 dB on the execution of the Minimum Taxation Directive (2022/2523) to ensuring a global minimum level of taxation for multinational enterprise groups and
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Belgium passes draft bill on GloBE rule
On 14 December 2023, the Belgian parliament approved the draft bill to implement the global minimum tax, Pillar 2, into Belgian law. On 30 November 2023, the draft law for implementing the global minimum tax Pillar Two was accepted by the Belgian
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Bulgaria: National Assembly approves Pillar 2 global minimum tax rules
On 12 December 2023, Bulgaria's National Assembly declared the approval of amendments to key tax laws, namely the Local Taxes and Fees Act, the Value Added Tax Act and the Corporate Income Tax Act. Notably, significant changes were made to the
See MoreHungary publishes GloBE laws in the official gazette
On 30 November 2023, Hungary published Law LXXXIII of 2023 on the amendment of individual tax laws and Law LXXXIV of 2023 on additional taxes in Gazette No. 171 of 30 November 2023. The recently enacted laws ensure a global minimum tax level and
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World Tax Brief: December 2023
Albania Rates-National/Federal: Albania enacted Instruction No. 26 on 19 September 2023, implementing the new Income Tax Law No. 29/2023 effective from 1 January 2024. Key changes include a standard 15% corporate income tax rate, with reduced
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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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Latvia announces to implement pillar two minimum tax rules partially
Latvia's Ministry of Finance announced it had finalized a draft legislation for partially implementing the Pillar 2 global minimum tax (GloBE) rules as per Council Directive (EU) 2022/2523 of 14 December 2022. The partial implementation
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Hong Kong updates guidance on FSIE regime
The Hong Kong Inland Revenue Department updated the guidance on the new Foreign-Sourced Income Exemption (FSIE) regime. The updated guidance is a continuation of previously published draft updates initially released when the Bill was
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US: IRS publishes additional interim guidance for the new corporate alternative minimum tax (CAMT)
On 15 December 2023, the United States Department of Treasury and the Internal Revenue Service (IRS) declared the issuance of Notice 2024-10, which clarifies additional interim guidance on the new corporate alternative minimum tax
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UAE: FTA publishes guidance on taxation of extractive business and non-extractive natural resource business
On 12 December 2023, the UAE Federal Tax Authority (FTA) provided the Corporate Tax Guide on Taxation of Extractive Business and Non-Extractive Natural Resource Business - CTGEPX1. This guide is designed to provide general guidance on Extractive
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Kazakhstan’s Transfer Pricing Legislative Amendments 2023
Kazakhstan is undergoing a pivotal transformation in its transfer pricing framework, marked by the Majilis' approval of substantial amendments to the existing legislation. The aim is to curb revenue losses, prevent capital outflow, and align with
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Australia to halt deductions for ATO interest charges
On 13 December 2023, the Australian Taxation Office (ATO) announced that the government will amend the tax law to deny deductions for ATO interest charges as part of the 2023–24 Mid-Year Economic and Fiscal Outlook (MYEFO). This measure is not yet
See MoreUS: IRS publishes guidance regarding the foreign tax credit and dual consolidated losses in relation to the GloBE model rules
The U.S. IRS has published Notice 2023-80, which outlines the guidance regarding the foreign tax credit and dual consolidated losses in relation to the GloBE Model Rules. The Notice also includes the Extension and Modification of the Temporary
See MoreRussia announces transfer pricing changes from 2024
On 27 November 2023, Russia issued Law No. 539-FZ in the Official Gazette, which outlines several amendments to the country’s transfer pricing regime. A summary of several key changes is outlined below: Secondary adjustments treated as
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Papua New Guinea: BEPS MLI enters into force
On 1 December 2023, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Papua New Guinea. Regarding the tax treaties between Papua New Guinea and other
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Netherlands: Senate passes public CbC reporting bill
The Dutch Senate (upper house of parliament) has passed the bill for implementing public Country-by-Country (CbC) reporting as required by Directive (EU) 2021/2101. The bill facilitates the partial implementation of Council Directive (EU) 2021/2101,
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