Czech Republic Rates-Special tax rate: The Ministry of Finance of the Czech Republic has released a proposed bill in accordance with EU directive on global minimum tax that outlines the implementation of the top-up tax for tax periods beginning on or after 31 December 2023.
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Denmark Rates-Special tax rate: On 23 June 2023, the Danish Ministry of Taxation introduced a draft bill for public feedback. This proposal aims to adopt the EU’s minimum tax directive, in accordance with the OECD’s Pillar Two Model Rules. The Danish government intends to follow the directive’s requirements to implement the 15% global minimum tax rules by 31 December 2023.
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Submission of returns: The Danish tax authority has extended the deadline for submitting the annual corporate income tax return from 30 June 2023 to 25 August 2023. Therefore, the new deadline for transfer pricing documentation submission is now 24 October 2023 instead of 29 August 2023.
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Estonia Rates-National/ Federal: The Estonian Parliament approved Income Tax Act and Defense Service Act Amendment Act 148 SE which increases corporate income tax rates to 22%. The income tax rate for credit institutions will be raised to 18%. The increased rate will be effective from 1 January 2025.
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Hungary Rates-Special tax rate: Hungary released Government Decree No. 206/2023 in the Official Gazette amending Decree No. 197/2022 regarding temporary windfall taxes on additional profits. The decree includes extension of certain taxes until 2024 and making adjustments to the tax base and tax rates. The Decree No. 206/2023 entered into force on 31 May 2023 and the Decree No. 197/2022 will expire on 1 January 2025.
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Ireland Rates-Special tax rate: Mr. Eamon Ryan, the Minister for the Environment, Climate and Communications announced the publication of the Energy (Windfall Gains in the Energy Sector) (Temporary Solidarity Contribution) Bill 2023. This Bill provides for a temporary solidarity contribution on windfall gains made in 2022 and 2023 by the fossil fuel production and refining sector.
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Mexico Incentives: The Mexican announced a decree introducing tax incentives for companies that decide to invest in the Interoceanic Corridor’s development hubs. The decree aims to promote economic development in the disadvantaged southeast region. The key tax incentives include a complete waiver of Income Tax (ISR) for the initial three years of business operation. From the fourth to the sixth year, companies will be entitled to 50% tax reduction, it may reduce to 90%.
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Mongolia Incentives-Industry/Manufacturing: The Mongolian government submitted a proposal to Parliament to amend the CIT law, providing a tax credit for thermal and electric power production sector. According to the proposal, companies engaged in manufacturing primary and auxiliary equipment or machinery involved in producing thermal power of 1.5 megawatts or more, and/or electric power of 5 megawatts or more, will be eligible for a tax credit of 90% until 31 December 2029.
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Norway Rates-Special tax rate: On 6 June 2023, the Norwegian Ministry of Finance published a consultation paper on the implementation of the Global minimum tax rules. The top-up tax would apply to large multinational groups with consolidated revenues of at least €750 million in two of the prior four years.
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Switzerland Rates-Special tax rate: On 18 June 2023, Switzerland held a vote and successfully passed a constitutional amendment to adopt Pillar One and Pillar Two of the OECD/G20 BEPS 2.0 project, thereby establishing the legal framework for their implementation. The approved amendment allows the Swiss government to implement global anti-base erosion (GloBE) rules, including the domestic top-up tax, through an implementation ordinance.
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Tanzania Taxation of capital gains: On 15 June 2023, the Finance Minister presents the Budget for 2023/24 to the Parliament providing a comprehensive overview of the tax measures. Tax measures include exempt Capital Gain Tax on internal restructuring of the mining companies and reduce Capital Gain Tax from 10% on profits to 3% of the sales value or the appraised land value (whichever value is higher).
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Thailand Rates-Reduced rates: The Thai Board of Investment (BOI) approved rules that introduces a reduced tax rate. The objective behind this regime is to address the repercussions of the implementation of the global minimum tax rule. Under this scheme, eligible companies that qualify for tax exemptions through BOI incentives can benefit from a reduced corporate tax rate of 10%.
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United Kingdom Rates-Special tax rate: The HMRC has published partial draft guidance on multinational top-up tax and domestic top-up tax, following their introduction in the Spring 2023 Finance Bill. Multinational top-up tax is a new tax on multinational enterprise groups with annual revenue of €750m or more. A top-up tax will be charged on the United Kingdom (UK) parent members when a subsidiary is located in a non-UK jurisdiction, and the group’s profits arising in that jurisdiction are taxed at a rate below the minimum effective tax rate of 15%.
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United States Rates-Surcharge: Connecticut Governor Mr. Ned Lamont signed the budget bill (H.B. 6941) which includes an extension of the business tax surcharge. The business tax surcharge of 10% has been extended for an additional three years, covering the income years from 2023 to 2025.
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Mitigation of penalties: The US Department of Treasury and the Internal Revenue Service jointly issued Notice No. 2023-42, which will grant penalty relief for corporations that did not pay estimated tax in connection with the new corporate alternative minimum tax (CAMT). The Inflation Reduction Act created the CAMT, which imposes a 15% minimum tax on the adjusted financial statement income of large corporations for taxable years beginning after 31 December 2022.
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