Belgium proposes new draft law for CFC rules
The Belgian government has submitted a new draft bill to parliament for implementing stricter rules concerning the taxation of the undistributed income of a controlled foreign company (CFC), shifting from model B (targeting tax avoidance
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Spain releases 2024 FTT list for companies
On 13 December 2023, the Spanish Tax Agency released the list of companies whose market capitalization value surpassed EUR 1 billion as of 1 December 2023. The list pertains to financial transaction tax (FTT). The financial transactions tax (FTT)
See MoreGloBE rules to be enforced from January 2024 despite major challenges
The OECD framework Two-Pillar Solution the global corporate minimum tax rate of 15% (Model GloBE Rules), imposed on large multinational companies with annual revenues of $790 million (€750 million) a proposal drafted by the OECD alongside G-20,
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Spain: Valencia & Catalonia propose retroactive personal income tax reductions (IRPF) for FY 2023
The Generalitat of Catalonia is working on reducing the regional section of the Personal Income Tax (IRPF). The “Govern” proposes in the budget accompanying law, cutting one percentage point – from 10.5% to 9.5% – the first tranche of the
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OECD: 2022 Peer Review Reports on the Exchange of Information on Tax Rulings
On 13 December 2023 the OECD released the 2022 Peer Review Reports on the Exchange of Information on Tax Rulings. The latest annual peer review reports cover 131 Inclusive Framework member jurisdictions and jurisdictions of relevance. The BEPS
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El Salvador: Congress extends tax amnesty until December 2023
El Salvador’s Congress has passed a tax amnesty, which is open to taxpayers only until 31 December 2023 and permits regularizing monthly and/or annual obligations (including customs) arising until September 2023. Legislative Decree No. 875
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Brazil tax reform brings challenges to service sectors
The new Brazilian transfer pricing rules align with the OECD standard and are a radical change to the analysis of intra-group transactions, and offer several implementational challenges. Besides, the tax reform (PEC 45/2019) is being discussed in
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Argentina: Newly elected government announces tax reforms
On 10 December 2023, the recently elected Government took power and has announced a series of structural economic and tax measures, including a significant simplification and reduction in applicable taxes. One of the measures announced has been
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Poland: Draft bill raises limits for tax-deductible costs
On 11 December 2023, Poland’s Lower House of Parliament received a draft law from the government in which it amended the Act on Personal Income Tax and the Act on Corporate Income Tax. The draft law increases the applicable limits to 100% for the
See MoreBrazil proposes to modify interest on net equity for 2024
On 30 November 2023 and 5 December 2023, Brazil’s Valor Econômico newspaper published a report stating that the Ministry of Finance of Brazil has completed the draft of a new proposal to amend the Interest on Net Equity (INE) mechanism. The
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Kazakhstan announces amendments to its tax laws
On 12 December 2023, Kazakhstan published Law No. 45-VIII of 12 December 2023 in the Official Gazette, providing various amendments to its tax laws including digital assets. The key amendments are as follows: The amendment of the new limit on
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Kazakhstan explains the tax refund procedure
On 8 December 2023, the State Revenue Committee of the Ministry of Finance of the Republic of Kazakhstan explained the procedure for returning an overpaid amount of tax, payment to the budget, and penalties, as well as the procedure for offsetting
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Algeria announces supplementary finance law for 2023
In November 2023, Algeria published the Supplementary Finance Law for 2023 in the Official Gazette. The key tax measures of the law include: A new transfer pricing declaration obligation has been introduced, requiring taxpayers to submit an
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Portugal approves State Budget for 2024
On 29 November 2023, the Portuguese parliament approved the State Budget for 2024 (Draft Law 109/XV/2), including some modifications proposed after the primary proposal on 10 October 2023. This budget includes the following tax measures:
See MoreKazakhstan: Proposed super profit tax on Banks
As of 2023, Kazakhstan's banking sector is at an important juncture with the proposed introduction of a super profit tax. The proposed tax reform in Kazakhstan focuses on introducing a super-profit tax on banks' earnings from government securities.
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Costa Rica announces CIT brackets for 2024
On 7 December 2023, the Ministry of Finance of Costa Rica published Executive Decree No. 44276-H in the Official Gazette, outlining the corporate and individual income tax brackets and rates for 2024. The updated corporate income tax is set at
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Kazakhstan: Draft amendments in the Tax Code
The website of the Senate of the Republic of Kazakhstan posted a draft of amendments to the Tax Code of the Republic of Kazakhstan for 2024. Some of the amendments are traditionally retrospective and enacted from past periods. Here are some of the
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Saudi Arabia: Government offers 30-year tax relief package to attract regional corporate headquarters
On 5 December 2023, the Ministry of Investment of Saudi Arabia (MISA), in coordination with the Ministry of Finance and the Zakat, Tax and Customs Authority (ZATCA) announced 30-year tax incentive package for the Regional Headquarters (RHQ) Program,
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