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
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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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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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: 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
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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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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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Australia: ATO deliberating on amended interest limitation rules
On 30 January 2024, the Australian Taxation Office (ATO) announced that it is seeking public input and feedback on guidance and advice related to the amendments to the interest deduction limitation rules, also known as thin capitalization rules.
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Germany: Bundesrat approves secondary credit market promotion Act
On 14 December 2023, upper house of parliament (Bundesrat) granted approval to the Secondary Credit Market Promotion Act. The Act had already received approval from the German Bundestag (lower house of parliament) on 13 December 2023 and is
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Malta releases guidelines about notional interest deduction (NID) rules
On 20 December 2023, Malta's Commissioner for Revenue published Version 1.1 of the Guidelines in Relation to the Notional Interest Deduction (NID) Rules. The Version 1.1 updates the sections regarding notional interest deduction (NID) approval,
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Australia: Government releases amended interest limitation rule
On 28 November 2023, the Australian government released the amendments and a supplementary explanatory memorandum to the interest limitation rules within the Treasury Laws Amendment (Making Multinationals Pay Their Fair Share—Integrity and
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Saudi Arabia: ZATCA releases drafts of new income tax and tax procedural laws for public consultation
On 25 October 2023, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) issued drafts of a new Income Tax Law and Zakat and Tax Procedures Law for public consultation. The public consultation period for comments on the drafts is open until 25
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