IMF Updates World Economic Outlook
On 17 January 2025 the IMF published the update to the World Economic Outlook, with the subtitle Global Growth: Divergent and Uncertain. The update notes that global growth is expected to remain stable at 3.3% in both 2025 and 2026, below the
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IMF Report looks at Australia’s Economic Position
On 23 December 2024 the IMF staff issued a report following consultations with Australia under Article IV of the IMF’s articles of agreement. Economic growth is projected increase gradually, from 1.2% in 2024 to 2.1% in 2025. Real income growth
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Poland sets base and margin rates for transfer pricing
Poland has published Notice No. 1105 in the Official Gazette on 21 December 2024, setting the base interest rates and margin interest rates for transfer pricing in individual and corporate income taxes. The regulation establishes base interest
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Italy announces penalty relief rules for hybrid mismatch rules
Italy's Ministry of Economy and Finance has published the Decree of 6 December 2024 outlining the penalty reliefs rules for violations of Italy's hybrid mismatch rules. The Decree’s penalty relief rules are taken from Legislative Decree No. 209
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India extends transfer pricing safe harbor rules to FY 2024-25, updates filing deadline for international transactions
India's Central Board of Direct Taxes (CBDT) has released Notification No. 124/2024 outlining the Income Tax (Tenth Amendment) Rules, 2024 on 29 November 2024. According to the amendment, the transfer pricing safe harbor rules under Rule 10TD of
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US: IRS and Treasury Plan to Issue Guidance on Streamlined Approach to Baseline Distribution Activities
In the IRS and Treasury Priority Guidance Plan for 2024/25, issued on 3 October 2024, there is a plan for a new section 482 guidance project to provide guidance for taxpayers consistent with Amount B of Pillar One. The OECD Amount B Guidance
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CJEU: Netherlands interest deduction limit on acquisition financing upholds freedom of establishment
The Court of Justice of the European Union (CJEU) issued a judgement on 4 October 2024 regarding Dutch interest deduction limits and freedom of establishment (Article 49 TFEU), based on a request from the Netherlands' Supreme Court. The Supreme
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Australia consults proposed provision denying deductions for ATO interest charges
The Australian Taxation Office (ATO) announced a proposed provision that will disallow the deduction of general interest charges (GIC) and shortfall interest charges (SIC) for income years beginning on or after 1 July 2025. After 1 July 2025,
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Cyprus publishes FAQs on new transfer pricing rules
The tax authority has published additional frequently asked questions (FAQs) numbered 25 – 43 to provide clarity on specific provisions of the new transfer pricing rules in Cyprus. Notably, FAQ 25 clarifies that taxpayers do not need to
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US: Kansas updates transition rules after separating from federal interest deductions
The Kansas Department of Revenue published Notice 24-16, on 7 August 2024, providing guidance on business interest deductions for tax years 2021 and beyond. For tax years 2018, 2019, and 2020, Kansas was coupled with the federal code and only
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Australia: Guidance on Thin Capitalisation Rules Published Online
Following the enactment of the new thin capitalisation laws in April 2024, the ATO has developed web guidance to assist taxpayers in applying the new rules, which are effective for income years commencing on or after 1 July 2023. Under the rules,
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Cyprus releases 2023-2024 reference rates for Montenegro and Cameroon notional interest deduction
The Cyprus Tax Department has published the 10-year government bond yield rate of Montenegro (in Euro) and Cameroon (in Euro) as of 31 December 2022 and 31 December 2023. These rates, when increased by 5%, are utilised as reference rates for
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France publishes interest rate caps on shareholder loan deductions for FY ending June-September 2024
France, on 29 June 2024, has published in its Official Journal the second quarter 2024 interest rates for companies whose fiscal year (FY) ends between 30 June and 29 September, 2024. The interest rates are used to calculate the deductibility of
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Australia: ATO finalises hybrid mismatch taxation rules
The Australian Taxation Office (ATO) released Taxation Determination (TD) 2024/4 - Income tax: hybrid mismatch rules - application of certain aspects of the 'liable entity' and 'hybrid payer' definitions on 3 July, 2024. TD 2024/4 is applicable
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Ireland updates guidelines on payment and receipt of interest, royalties without income tax deduction
Irish Revenue has released eBrief, updating Tax and Duty Manual 08-03-06 regarding the payment and receipt of interest and royalties without income tax deduction. The update clarifies the application of reduced withholding tax under double taxation
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Serbia releases 2024 arm’s length interest rates rulebook
Serbia’s Ministry of Finance has issued the rulebook on arm’s length interest rates for 2024. It was published in the official gazette on 31 May, 2024, and will take effect on 8 June, 2024. The rulebook sets distinct interest rates for
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Singapore updates tax guide for variable capital companies with new GST and deduction rules
The Inland Revenue Authority of Singapore (IRAS) published an e-tax guide (Second Edition) detailing the tax framework for variable capital companies (VCCs), a corporate structure designed for investment funds, on 31 May, 2024. The Second Edition
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Ireland updates guidance on relief from stamp duty and property transfers for associated companies
The Irish Revenue has released eBrief No. 142/24 on 21 May, 2024, which provides an updated guidance on the associated companies relief for stamp duty on conveyances and transfers of property between associated corporate bodies. Revenue eBrief
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