Italy amends windfall tax law for banks
On 5 October 2023, the Italian Parliament passed the amended Law No. 136, which converts into law Decree-Law No. 104 of 10 August 2023 to introduce Windfall tax for Italian banks and Italian branches of foreign banks. The amendments include
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World Tax Brief: October 2023
Argentina Payment of tax: On 4 September 2023, the Argentine Official Gazette published General Resolution No. 5411/2023, extending integrated tax payment deadlines for small business taxpayers. Based on Categories A, B, C and D tax payment
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Denmark: MoF issues draft bill to implement Pillar 2 global minimum tax
On 4 October 2023, the Danish Ministry of Finance (MoF) issued a draft bill for the implementation of the Pillar 2 global minimum tax rule in accordance with EU Council Directive 2022/2523 of 14 December 2022. The proposal seeks to establish a
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Malaysia revises public ruling on tax incentive for BSCs investors
On 4 October 2023, the Inland Revenue Board of Malaysia (IRBM) released Public Ruling No. 2/2023, which outlines the tax incentives offered to an investor who has invested in a BioNexus status company in Malaysia. The tax incentive granted to an
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Romania releases draft law on global minimum tax rule
On 4 October 2023, the Ministry of Public Finance in Romania opened a public consultation on a draft law and explanatory note for implementing the Pillar 2 global minimum tax as per the Council Directive (EU) 2022/2523 of 14 December 2022. The
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Japan: NTA publishes explanative guidance on global minimum tax
On 29 September 2023, the Japanese National Tax Agency (NTA) issued guidance on the income inclusion rule (IIR) under the OECD pillar two model which was introduced as part of the 2023 tax measures. The guidance explains how companies can use the de
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Latvia presents proposed tax measures for the 2024 budget
On 26 September 2023, the Latvian Ministry of Finance released an official statement announcing that the Cabinet of Ministers has reviewed an informative report on developing the National Tax Policy Guidelines for 2024-2027. The report includes
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Austria: MoF publishes draft law implementing Pillar Two global minimum tax
On 3 October 2023, the Austrian Ministry of Finance (MoF) published a draft law implementing the Pillar Two global minimum tax as per the Council Directive (EU) 2022/2523 of 14 December 2022. The draft law is open for public consultation which will
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France: FTA publishes update guidelines on DAC6
On 13 September 2023, the French tax authorities (FTA) revised their DAC 6 administrative guidelines in order to provide further clarification on hallmark D.1.b. This particular hallmark relates to the automatic exchange of information and
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Transfer Pricing Brief: October 2023
Armenia Compliance with BEPS standards: On 25 September 2023, Armenia deposited its instrument of ratification of the Multilateral Convention on the Implementation of Tax Treaty-Related Measures to Prevent BEPS (MLI). See the story in
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El Salvador: Ministry of Finance releases tax havens list for 2024
On 29 September 2023, El Salvador's Ministry of Finance released a new General Guide on tax havens for the 2024 fiscal year. This guide lists jurisdictions and territories deemed as tax havens due to their low or zero-tax regimes.  Payments
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Saudi Arabia: ZATCA releases proposed amendments to the income tax law
On 25 September 2023, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) released proposed amendments to the Income Tax Law for public consultation. The proposed amendments to the Income Tax Law primarily focus on the withholding tax applied
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Bulgaria launches public consultation to implement Pillar 2 global minimum tax
On 26 September 2023, the Bulgarian Ministry of Finance released a draft law for the implementation of the Pillar 2 global minimum tax rule in accordance with EU Council Directive 2022/2523 of 14 December 2022. The draft law is currently subject
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France submits finance bill for 2024 including Pillar 2 global minimum tax
On 27 September 2023, the government of France presented the 2024 Finance Bill to Parliament. The bill aims to combat inflation, reduce the national debt and promote sustainable development. The Finance Bill includes a provision to implement the
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Latvia publishes law transposing public CbC reporting into domestic law
On 27 September 2023, the Latvian government released the "Information on Revenue and Income Tax Disclosure Law" in the Official Gazette. This law outlines the framework for the adoption of public Country-by-Country (CbC) reporting, aligning Latvia
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Poland releases guidelines relating to cost-plus method in transfer pricing
On 29 September 2023, Poland published formal guidance regarding the application of the cost-plus method to ensure accurate valuation of transactions involving related entities for international tax purposes. The purpose of this guide is to provide
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Armenia deposits its instrument for the ratification of BEPS MLI
On 25 September 2023, Armenia deposited its instrument of ratification of the Multilateral Convention on the Implementation of Tax Treaty-Related Measures to Prevent BEPS (MLI). The Convention will enter into force in relation to Armenia on 1
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Austria: Ministry of Finance releases DAC6 reporting guidelines
On 12 September 2023, the Austrian Ministry of Finance published an updated guidance on the explanation and application of the rules of DAC6 in Austria. This update is a practical guide to understanding EU-MPfG compliance, based on questions and
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