Albania Liability to Tax: On 2 May 2023, the Law No. 29/2023 of 30 March 2023 (the new law) was published in the official gazette, effective on 1 January 2024. The new law will replace Law No. 8438 of 28 December 1998. The new law introduces several significant amendments to corporate income tax. These changes encompass a wider definition of tax residence, requirements for applying the dividend participation exemption, extended limitations on interest deductibility, and so on.
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Belgium Mode for Filing – e-Filing: On 28 April 2023, the Belgian Federal Public Service Finance made an official announcement regarding the launch of the Biztax e-service. This digital platform is aimed at facilitating the submission of corporate income tax (CIT) returns for the assessment year 2023 (2022 tax year).
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Czech Republic Rates-Special tax rate: On 15 May 2023, the Czech Ministry of Finance initiated a public consultation on a draft bill aimed at implementing the OECD’s Pillar Two global minimum tax rules. This implementation is in accordance with the EU Minimum Tax Directive 2022/2523. Public comments on the draft bill are requested by 12 June 2023.
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France Rates-Special tax rate: On 15 May 2023, the French tax authority released guidelines regarding the temporary solidarity contribution for fossil fuel sector. The temporary solidarity contribution is payable by legal entities or PEs engaged in business activities within France. The solidarity contribution rate is set at 33% on the taxable profit exceeding 120% of the average taxable profit in the preceding four fiscal years from 2018 to 2021.
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Hungary Rates-Special tax rate: On 29 March 2023, the Hungarian Official Gazette published Government Decree No. 100/2023 amending the provisions on windfall taxes on petroleum products imports from Russia. Under the decree, a windfall tax has been introduced on the profits of petroleum products. This tax is calculated at a rate of 2.8% on the net sales revenue, which is determined based on the annual report for the 2022 tax year.
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Lithuania Rates-Special tax rate: On 9 May 2023, Lithuania has enacted Law No. XIV-1936 introducing a temporary solidarity contribution on banks operating within the country. The contribution will be payable for the years 2023 and 2024, with a rate of 60% imposed on net interest income exceeding the average of the previous four years, increased by 50%. For the calculation, the reference period is set as 2018 to 2021 for 2023, and 2019 to 2022 for 2024.
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Netherlands Rates-Special tax rate: The Dutch Government has submitted a draft legislation to the Parliament in order to incorporate the BEPS 2.0 – Pillar Two requirements into its domestic laws. The Dutch proposal is based on the European Union (EU) Directive issued on 14 December 2022, which aims to implement the OECD Pillar Two agreement within the EU with a minimum effective tax rate of 15% for businesses falling within its scope.
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New Zealand Rates-Special tax rate: New Zealand has adopted the OECD’s Base Erosion and Profit Shifting (BEPS) pillar two global minimum tax rate proposal. The Global Anti-Base Erosion (GloBE) rules are the main component of Pillar Two. The rules are designed so that MNEs with annual revenues above €750 million pay a minimum 15% effective tax rate.
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Panama Liability to Tax: On 13 April 2023, the Panamanian tax authority released Resolution No. 201-3346. According to Resolution 201-3346, the new simplified conditions state that an individual or a legal entity will be categorized as a large taxpayer if their income or assets exceed PAB 20 million.
See the story in RegfollowerSanctions for non-compliance – Late returns: On 17 April 2023, the Panamanian tax authority (DGI) released Resolution No. 201-3486, which introduced penalties for employers who do not submit their monthly withholding tax returns Form 03 for employment income. The penalty ranges from Panamanian Balboa 100 to 1000 for not timely filing monthly withholding return Form 03.
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Spain Mode for Filing – e-Filing: Spain has published an “Order HFP/523/2023 of 22 May 2023” in the Official Gazette, approving the forms and instructions for the corporate income tax returns for the period starting between 1 January and 31 December 2022. The regulation will come into effect on 1 July 2023. The forms must be submitted electronically via the Tax Agency website.
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Sri Lanka Mode for Filing – e-Filing: Filing of tax returns through the e-service platform (e-filing) is mandatory for all taxpayers from the year of assessment commencing on April 1, 2023 (2023/2024). However, the Commissioner General may authorize to furnish manual tax returns based on the just and equitable reasons of taxpayers.
Computation of taxable income: No deduction shall be allowed to a person in computing his income, and amounts incurred by him shall not be considered as cost of an asset, where such person pays those amounts to another person by cash exceeding Rs. 500,000 in a day, or in respect of a single transaction, or in respect of a series of single transactions relating to one event.
See the story in RegfollowerComputation of taxable income: The IRD has released Circular No. SEC/2023/E/03 with detailed guidelines for calculating income tax for the assessment year beginning on 1 April 2022. The circular takes into consideration the amendments introduced by the Inland Revenue (Amendment) Act No. 45 of 2022, which require the computation of income tax payable for two separate 6-month periods during the tax year.
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Switzerland Rates-Special tax rate: On 24 May 2023, the Swiss Federal Council made an announcement outlining the introduction of the OECD Pillar 2 global minimum tax. This implementation is now awaiting a referendum vote scheduled for 18 June 2023. If this is accepted, the Federal Council can temporarily introduce the supplementary tax by means of an ordinance.
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UAE Computation of taxable income: On 23 May 2023, the UAE Ministry of Finance (MoF) published Decision No. 126 of 2023 on the general rules for limiting the deduction of interest for corporate tax purposes. To determine the deductible interest from taxable income, the higher value is considered: AED 12,000,000 or 30% of Earnings Before Interest, Taxes, Depreciation, and Amortization (EBITDA).
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UK Facilitating tax evasion: The UK has issued a consultation document on more severe penalties for promoters of tax avoidance, inviting comments from interest parties by 22 June 2023. The document proposes a new criminal offence that would apply to promoters who continue to promote tax avoidance schemes that have been specified in a ’Stop Notice’ issued by HMRC. The consultation document sets out the scope of the policy and looks at how it can be implemented.
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