Argentina Incentives: The Argentine Executive Branch proposed a bill introducing a new “Incentive Regime for Large Investments”. It aims to provide predictability and stability for investors committing to large projects, offering tax and customs incentives such as a 25% income tax rate for Sole Purpose Vehicles (SPVs) and accelerated amortization mechanisms.
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Ecuador Withholding rates: The Internal Revenue Service (SRI) issued Resolution No. NAC-DGERCGC24-00000003 on 12 January 2024, outlining withholding tax rates for various economic activities under the new monthly self-withholding obligation for large taxpayer companies. The rates range from 1.25% to 10.0%, with failure to withhold resulting in interest charges and fines equal to 100% of the tax not withheld. This obligation took effect in January 2024.
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France Rates-Special tax rate: France has published the Finance Law for 2024 in the Official Gazette, which introduces measures to implement the Pillar 2 global minimum tax rule, ensuring a minimum tax level of 15% for large multinational groups. This includes the Pillar 2 income inclusion rule (IIR) and undertaxed payment/profit rule (UTPR). The rules generally apply for financial year beginning on or after 31 December 2023.
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Greece Rates-Special tax rate: On 9 January 2024, Greece’s Ministry of Economy and Finance presented draft legislation to the cabinet aligning national law with the EU Pillar 2 directive. The bill establishes a minimum tax rate of 15% for multinationals and large domestic corporations with turnovers exceeding 750 million euros. Non-compliance may result in a supplemental tax of up to 15% of profits.
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Korea, Rep Of Rates-Special tax rate: The South Korean tax authority has announced enforcement of the new Pillar 2 global minimum tax requirements starting from 1 January 2024. They have formed an international tax response team to administer minimum tax rules and participate in discussions for implementing Pillar 1 rules. MNE groups with consolidated revenue over EUR 750 million in two or more of the previous four fiscal years are subject to the minimum tax rules, with a new return requirement due by June 2026.
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Latvia Rates-Special tax rate: On 30 January 2024, the Latvian Cabinet approved a draft law for introducing a global minimum tax rule for large enterprise groups. This draft law, pending approval by the parliament and publication in the Official Gazette, aligns with EU Directive 2022/2523. The draft law excludes the income inclusion rule (IIR) and undertaxed payment/profit rule (UTPR), which will be applied no later than fiscal years beginning on or after 31 December 2029.
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Netherlands Rates-Special tax rate: The Dutch Tax Administration has released guidance on the Minimum Tax Act 2024, following EU Directive 2022/2523. The guide includes submitting an additional tax information declaration within 15 months after the fiscal year’s end (or 18 months for the first year). Additionally, taxpayers must file an extra tax return and make payment if additional tax is owed, with the deadline set at 17 months following the end of the reporting fiscal year (or 20 months for the first year). These measures are part of implementing the global minimum tax under Pillar 2 and ensuring international tax compliance.
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Norway Rates-Special tax rate: Norway enacted the Supplementary Tax Act on 12 January 2024, implementing global minimum tax measures. It applies to MNE groups with annual revenue of EUR 750 million in two of the past four years, establishing an income inclusion rule and domestic minimum top-up tax to ensure a 15% effective tax rate. Effective for financial years starting after 31 December 2023.
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Romania Rates-Special tax rate: Romania enacted Law No. 431, published in the Official Gazette on 5 January 2024. It implements the Pillar 2 global minimum tax requirements, as per EU Council Directive 2022/2523. The law introduces the income inclusion rule (IIR) and undertaxed payment/profit rule (UTPR) to ensure a minimum tax level of 15% for MNE groups with annual consolidated revenue of at least EUR 750 million in two of the preceding four fiscal years. Effective from 8 January 2024, it applies to financial years starting on or after 31 December 2023.
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Saudi Arabia Mitigation of penalties: The Zakat, Tax and Customs Authority (ZATCA) extends its “Cancellation of Fines and Exemption of Penalties” initiative until 30 June 2024, aiming to aid taxpayers affected by COVID-19. The initiative covers fines for late registration, payment, and filing of returns across tax laws, as well as VAT-related fines. To benefit, taxpayers must register, submit all pending returns, pay principal tax debt, and can request installment plans.
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Slovenia Rates-Special tax rate: The Minimum Tax Act was published in Slovenia’s Official Gazette on 21 December 2023, implementing the Pillar 2 global minimum tax rule as per EU Council Directive 2022/2523. It implements a 15% minimum tax for MNE groups with over EUR 750 million in annual revenue in two of the past four years. The Act came into force on 22 December 2023, applying to financial years starting on or after 31 December 2023.
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Vietnam Incentives-Industry/manufacturing: The Vietnam Ministry of Planning and Investment introduces draft decree to establish an Investment Support Fund in response to the global minimum tax rules enacted in November 2023. The fund aims to maintain Vietnam’s investment competitiveness by offering incentives, particularly for high-tech research and development. Eligibility criteria include significant investment or high annual revenue, targeting large foreign-invested enterprises engaged in high-tech production or advanced technology application.
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