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
See MoreAustralia: 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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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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France: Tax Authority updates interest deduction rates for shareholder loans
The French tax authority has updated the interest rates used to define the deductibility of interest payments made to shareholders. These updates are pertinent to companies with fiscal years ending between 31 December, 2023, and 29 June,
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Germany: Parliament approves law for growth, investment, and tax simplification
The Bundesrat, upper chamber of the German Parliament, gave its approval to the compromise proposal for the "Act aimed at Enhancing Growth Opportunities, Investment, and Innovation, while Simultaneously Simplifying Taxation and Ensuring Fairness" on
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Germany: Bundesrat approves growth opportunities Act
On 22 March 2024, the German upper house of parliament (Bundesrat) declared its endorsement of the Growth Opportunities Act. The lower house of parliament (Bundestag) gave its approval to the Act on 23 February 2024. The bill, initially proposed as
See MoreAustralia: ATO initiates consultation on draft tax determination for hybrid mismatch rules
The Australian Taxation Office (ATO) released the draft Taxation Determination (TD) 2024/D1 - Income tax: hybrid mismatch rules - application of certain aspects of the 'liable entity' and 'hybrid payer' definitions. This draft Determination
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Cyprus announces 2024 reference rates for notional interest deduction
On 7 March 2024, the Cyprus Tax Department announced the release of reference rates for 2024 that will be used to calculate the notional interest deduction (NID) on new equity investments. According to regulations, the NID rate is equivalent to the
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Bolivia defers deadline for submitting and paying financial transaction tax
On 4 March 2024, Bolivia’s tax authority, the National Tax Service (Servicio de Impuestos Nacionales), released the RND N°102400000007. In this guidance, the tax authorities have extended the deadline for submitting affidavits and paying taxes
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South Africa: Finance Minister presents the Budget for 2024
On 21 February 2024, Enoch Godongwana, South Africa's Minister of Finance announced the budget 2024. Key tax highlights from the 2024 budget following: Enforcing the global minimum corporate tax: The OECD/G20 Inclusive Framework on Base Erosion
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Slovenia enacts adjustments to permanent establishment and interest limitation regulations
On 9 February 2024, Slovenia officially released the Act amending the Corporate Income Tax Act (ZDDPO-2T) in the Official Gazette. The provisions outlined in the legislation encompass: Preventing PE status misuse: New rules limit on strategies
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