World Tax Brief: November 2023

ArgentinaPayment of tax: The Argentine Federal Tax Authority (AFIP) introduced General Resolution No. 5424/2023, requiring income tax prepayment for companies in Financial Intermediation, Insurance Services, or registered as payment service providers. Eligible companies with taxable income over AR$600m must prepay 15% of net taxable income.
See the story in RegfollowerAustraliaThin capitalization rules: The Australian Treasury Department opened a consultation on an exposure draft bill to amend the interest limitation rules on 18 October 2023. According to the Economics Legislation Committee’s final report, the government has now prepared exposure draft parliamentary amendments to ensure the new thin capitalization rules are appropriately targeted. The consultation period ends on 30 October 2023.
See the story in RegfollowerIncentives: The Australian Taxation Office (ATO) has reminded taxpayers about the importance of registering eligible R&D activities within 10 months from the end of the income year to claim the R&D Tax Incentive. To claim the R&D Tax Incentive through the ATO, taxpayers are required to register their eligible R&D activities. This registration must be completed within 10 months from the end of the income year.
See the story in RegfollowerAustriaRates-Special tax rate: Austria’s Ministry of Finance has introduced a draft law to implement the Pillar 2 global minimum tax, aiming for a 15% minimum tax for multinational groups with annual consolidated revenue of at least EUR 750 million. The draft includes the Pillar 2 income inclusion rule (IIR) and undertaxed payment/profit rule (UTPR). Additionally, Austria introduces a qualified domestic minimum top-up tax (QDMTT) aligned with the BEPS Inclusive Framework.
See the story in RegfollowerCyprusRates-Special tax rate: The Cyprus Ministry of Finance has proposed draft legislation aligned with OECD’s Pillar Two global minimum tax rules. The legislation aims to impose a 15% minimum effective tax rate on multinational with annual consolidated revenue over EUR 750 million. The legislation is in line with international efforts to ensure fair taxation, and the draft is open for public consultation until 31 October 2023.
See the story in RegfollowerCzech RepublicRates: The Czech Chamber of Deputies approved a tax reform bill increasing the corporate tax rate from 19% to 21%, repealing 22 tax exemptions, and consolidating single VAT rates of 12%. The Senate’s approval is now required to be effective from 1 January 2024.
See the story in RegfollowerDenmarkRates-Special tax rate: Denmark has published draft bill L 5 to implement the Pillar 2 global minimum tax aligned with Council Directive (EU) 2022/2523 of 14 December 2022. The bill includes the Income Inclusion Rule (IIR) and Undertaxed Payment/Profit Rule (UTPR) to ensure a minimum 15% tax. The law takes effect from fiscal years beginning on or after 31 December 2023, with certain provisions applicable from 31 December 2024.
See the story in RegfollowerFinlandRates-Special tax rate: Finland’s Ministry of Finance has published a draft bill to implement the Pillar 2 global minimum tax, ensuring a 15% minimum tax for MNE groups with annual consolidated revenue of at least EUR 750 million. The bill includes income inclusion rule (IIR) and qualified domestic minimum top-up tax (QDMTT) takes effect from fiscal years beginning on or after 31 December 2023. While the undertaxed payment/profit rule (UTPR) will generally apply for financial periods beginning on or after 31 December 2024.
See the story in RegfollowerIrelandRates-Special tax rate: Mr. Michael McGrath TD, the Minister for Finance has published the Finance (No. 2) Bill 2023. The Bill implements the 15% Pillar Two minimum effective tax rate for large groups and companies by transposing the EU Minimum Tax Directive (Council Directive (EU) 2022/2523 of 15 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union) into Irish law.
Incentives: The R&D Tax Credit provides for a 25% tax credit for all qualifying R&D expenditure and the Bill provides for an increase to the rate of the credit to 30%.
See the story in RegfollowerItalyRates-Special tax rate: On 5 October 2023, the Italian Parliament passed an amended law No. 136 introducing a Windfall Tax for banks. Key changes include calculating increased interest margins based on comparing FY2023 to FY2021 with a minimum floor of 10%, a tax ceiling of 0.26% of total risk-weighted assets, and the option for banks to set aside an amount equal to or greater than 2.5 times the Windfall Tax in a non-distributable reserve instead of paying the tax in cash.
See the story in RegfollowerMalaysiaTaxation of capital gains: On 13 October 2023, Malaysian Prime Minister and Finance Minister tabled the government’s 2024 budget. In line with the Budget 2023 announcement to implement Capital Gains Tax (CGT) on the disposal of unlisted shares for companies, it is proposed CGT rate ranges from 2% to 10%.
Incentives: To attract quality investment, the Government has introduced the Principal Hub tax incentive, that includes reduced income tax rate of 0%, 5% and 10% subject to certain condition.
Rates-Special tax rate: Taking into account feedback from the industry and latest international developments, the Government is expected to implement the global minimum tax in 2025 and only applicable to companies with a global income of at least 750 million euros.
See the story in RegfollowerRomaniaRates-Special tax rate: The Ministry of Public Finance in Romania has opened a public consultation on a draft law and explanatory note for implementing the Pillar 2 global minimum tax rule. The draft law includes the income inclusion rule (IIR) and the undertaxed payment/profit rule (UTPR) to guarantee a minimum tax rate of 15% for Multi-National Enterprises (MNE) groups with annual consolidated revenue of EUR 750 million or more in a minimum of two out of the previous four fiscal years.
See the story in RegfollowerSaudi ArabiaRates-Withholding rates: Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) proposed amendments to the Income Tax Law for public consultation. The proposed amendments include new withholding tax rates include 5% for interest, 15% for royalties, 5% for rent, 5% for dividends (with exceptions), and 10% for services.
See the story in RegfollowerUkraineRates-Special tax rate: Ukraine’s parliament passed Draft Law 9656-d, proposing a temporary corporate income tax increase for banks to 36% from January 2024 to December 2025. This is double the standard rate, and banks cannot use carried forward losses during this period.
See the story in Regfollower

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