Kenya: Tax measures in finance act 2023
On 3 July 2023, the Kenya Revenue Authority published the Finance Act 2023, following its presidential assent on 26 June 2023. The act includes the following notable provisions related to corporate income taxation. Digital assets
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Canada plans to enact DST in 2024
On 12 July 2023, Canadian Deputy Prime Minister and Minister of Finance said “two years ago, we agreed to pause the implementation of our own Digital Services Tax (DST), in order to give time and space for negotiations on Pillar One. But we were
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Panama introduces updated income tax return forms
On 27 June 2023, Panama officially published Resolution No. 201-4370/2023 in the Official Gazette, that introduces updated forms for filing income tax returns. These new forms are applicable to various entities, including individual taxpayers, legal
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UK amends CbC notification Requirement
On 5 July 2023, the House of Commons in the United Kingdom (UK) made a significant decision by accepting Statutory Instrument No. 752/2023 to amend tax regulations on BEPS country-by-country (CbC) notification requirement. The UK government has
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Ireland: Revenue issues guidance for platform operators under DAC7
On 5 July 2023, the Irish Revenue issued eBrief No. 155/23, which provides guidance for platform operators for the exchange of information on income generated through digital platforms (DAC7). Council Directive 2011/16/EU (DAC) provides for the
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Switzerland plans to extend loss carryforward time limit
The Switzerland Federal Council has recently made an announcement indicating that there is an ongoing parliamentary consideration of a proposal to extend the period for carrying forward losses from 7 years to 10 years. The primary objective of this
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Peru shifts from LIBOR to SOFR for lower withholding tax on nonresident interest
On 29 June 2023, Peru published Supreme Decree 137-2023 in the Official Gazette for the adoption of the Secured Overnight Financing Rate (SOFR) to replace the London Interbank Offered Rate (LIBOR). The Decree came into force on 30 June 2023. This
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Colombia: Ministry of Finance issues draft decree on significant economic presence rule
On 30 June 2023, the Colombian Ministry of Finance issued a draft decree on the significant economic presence (SEP) rule as a part of Law 2277 of 2022 (tax reform law). The SEP rule was introduced in the context of digital services taxation. The SEP
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Lithuania: Seimas moves one step closer to tax reform
On 27 June 2023, the Lithuanian parliament (Seimas) gave its preliminary confirmation, to a tax reform package proposed by the finance minister. The reform measures include: Proposed changes to the tax framework encompass various aspects of
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France issues decree on temporary solidarity contribution for electricity producers
France has issued a decree outlining the guidelines for declaring and remitting the temporary solidarity contribution within the electricity production sector. The contribution is levied on electricity producers in France, with certain exceptions,
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Luxembourg: Tax Authority updates FAQs on DAC6
On 30 June 2023, the Luxembourg Tax Authority updated the frequently asked questions (FAQs) concerning the mandatory disclosure and exchange of cross-border tax arrangements (DAC6). The latest update clarifies the following measures:
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US: IRS issues practice unit on categorization of income and taxes into proper basket for FTC
On 15 May 2023, the U.S. IRS published a practice unit regarding Foreign Tax Credit - Categorization of Income and Taxes Into Proper Basket. This Practice Unit is revised to address changes from the implementation of the Tax Cuts and Jobs Act (TCJA)
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Australia: New legislation proposes amendments to interest limitation rule
Legislation has been introduced in Parliament, suggesting amendment to the interest limitation or thin capitalization rules, which is closely align with the exposure draft legislation. If approved, these rules will be effective for income years
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On 16 May 2023, the IRS Large Business and International (LB&I) division issued two practice units in relation to interest expense limitations for related party loans. Interest Expense Limitation on Related Foreign Party Loans Under IRC
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Transfer Pricing Brief: July 2023
Brazil Scope of transfer pricing rules: On 14 June 2023, the president signed the Law No. 14,596 adopting Provisional Measure No. 1,152, which enacts significant changes to the Brazilian transfer pricing system that is aligned with the
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Hong Kong: IRD issues circular letter extending due date for D code returns
On 29 June 2023, the Inland Revenue Department (IRD) published a Circular Letter announcing an extension of the deadline for “D” code profit tax returns. In the letter, IRD explains that given the real difficulties faced by businesses and
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Mexico: BEPS MLI enters into force
On 3 July 2023, OECD published the updated position of signatories’ countries regarding the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Accordingly, MLI entered into force for
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Germany passes law for public Country-by-Country reporting
On 21 June 2023, Germany released the Law introducing Public Country-by-Country (CbC) reporting. This legislation is in accordance with Directive (EU) 2021/2101 and is applicable to multinational and high-revenue companies, whether related or
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