The OECD released an announcement on 27 August 2024 highlighting that jurisdictions have made further progress in addressing harmful tax practices through the implementation of the international standard under BEPS Action 5. This is evidenced by today’s release of the latest results of the reviews by the Forum on Harmful Tax Practices (FHTP) of preferential tax regimes.

Conclusions were drawn regarding various regimes in Armenia, Bulgaria, Croatia, Eswatini, and Hong Kong. At its May 2024 meeting, the FHTP reached the following new conclusions on five regimes as part of the implementation of the BEPS Action 5 minimum standard on harmful tax practices:

Jurisdiction Regime Status Comments
Armenia Free economic zones IP part: Abolished Ring-fencing removed. Substance requirements (non-IP) in place.
Bulgaria Tonnage tax Not harmful No harmful features
Croatia Investment promotion act Under review Regime under review by the FHTP.
Croatia Tonnage tax Not harmful No harmful features
Eswatini Special economic zones IP part: Abolished[1] Ring-fencing removed. Substance requirements (non-IP) in place.
Hong Kong Profits tax concession for aircraft lessors and aircraft leasing managers Not harmful Grandfathering in accordance with FHTP
Non-IP part: Not harmful (amended)[2] Grandfathering in accordance with FHTP timelines
Non-IP part: Not harmful (amended) Grandfathering in accordance with FHTP timelines

The total number of regimes reviewed by FHTP has now reached 326, with over 40% of those regimes being (or in the process of being) abolished. Learn more about BEPS Action 5 on harmful tax practices