Multinational Corporations and Profit Shifting:
Countries are implementing measures to combat profit shifting by multinationals.
- Australia’s court ruling against PepsiCo Inc. sets a precedent for handling multinational tax avoidance.
- Hungary’s laws for global minimum tax aim to prevent double non-taxation and specify non-deductible payments to certain jurisdictions.
Tax Incentives and Credits:
Targeted tax incentives promote research, development, and green practices.
- U.S. IRS guidance for clean vehicle manufacturers outlines compliance for the clean vehicle credit.
- New Zealand’s interpretation statement on R&D loss tax credits clarifies eligibility and operational guidelines.
Digital Economy and Taxation:
Tax laws are adapting to the digital economy, including digital assets.
- Hong Kong’s legislation enhances tax certainty for gains from equity disposals, addressing digital assets.
VAT and Excise Tax Adjustments:
Adjustments in VAT and excise taxes respond to economic conditions and fraud prevention.
- OECD’s report shows reduced excise taxes due to energy crisis responses.
- Malta’s new regulations for payment service providers aim to combat VAT fraud.
Tax Compliance and Enforcement Initiatives:
Enhanced tax compliance efforts include waivers and stricter reporting requirements.
- Nigeria’s FIRS offers complete waivers for prompt tax liability settlement.
- Mauritania extends transfer pricing rules to domestic transactions, enhancing compliance.
Personal Income Tax Revisions:
Personal income tax structures are being revised to adapt to economic and social needs.
- Luxembourg proposes varied rates for 2024 to accommodate different income levels.
Tax Treaties and Agreements:
Strengthening international tax cooperation with new treaties and amendments is a key focus.
- Angola-Switzerland’s treaty covers various taxes with specific provisions on service PE and withholding tax rates.
- San Marino-UK’s treaty includes zero withholding tax rates on dividends, interest, and royalties.
- Croatia and Cyprus are moving towards their first bilateral tax treaty.
- The Guernsey-Poland protocol amends the individual income tax treaty, adding BEPS-compliant provisions.
