January 8, 2024



Targeting Treaty Abuse and Enhancing Cross-Border Tax Transparency

  • Germany-Luxembourg Tax Treaty: Incorporates a ‘principal purpose test’ and new dividend taxation rules, specifically addressing treaty shopping and aligning with BEPS Action 6.
  • Singapore’s Enhanced Reporting for Foreign Income: Mandates comprehensive disclosure of foreign subsidiary earnings to increase transparency in international tax dealings.
  • Netherlands’ Refined Corporate Tax Compliance: Introduces detailed country-by-country reporting requirements for multinationals, aimed at preventing aggressive tax planning.

Global Harmonization of Tax Standards through BEPS Adoption

  • Armenia and Ivory Coast Embrace BEPS MLI: Implementing specific measures against treaty abuse and establishing dispute resolution mechanisms in line with BEPS actions.
  • Liechtenstein’s Pillar 2 Minimum Tax Compliance: Adopts a 15% minimum corporate tax rate for large multinationals, enforcing fair tax competition as per OECD guidelines.
  • Brazil’s Implementation of BEPS Action Items: Embraces various BEPS initiatives, including enhanced reporting and stricter rules on tax treaty abuse.

Strategic Enhancement and Expansion of International Tax Treaties

  • Cambodia-Turkey Tax Treaty: Establishes clear permanent establishment criteria and standardized withholding tax rates for passive incomes.
  • Ukraine’s Tax Treaty Modernization: Updates bilateral treaties with BEPS-compliant measures to prevent tax evasion and double taxation.
  • Australia-New Zealand Treaty Redefinition: Aims to eliminate double taxation, with a focus on cross-border income, including dividends and interest.

Tax Policies Adjusted for Economic Resilience and Environmental Sustainability

  • Saudi Arabia’s Extended Relief in Tax Penalties: Offers specific exemptions from late filing and under-reporting penalties as an economic relief measure.
  • Bermuda’s Alignment with Global Tax Norms: Implements a 15% corporate tax for large MNEs, targeting entities with revenues above €750 million as per OECD Pillar 2.
  • Ireland’s Green Energy Tax Incentives: Introduces reduced VAT rates for solar panel installations, promoting renewable energy investments.

National Tax Reforms in Response to Global Economic Shifts

  • Ukraine’s Comprehensive Tax Overhaul 2024-2030: Features corporate tax rate reductions and personal income tax system revisions for enhanced growth and compliance.
  • Greece’s Streamlined and Efficient Tax Code: Focuses on digitizing and simplifying tax processes to reduce complexities for businesses and individuals.

Advancing Digitalization in Tax Administration for Improved Compliance

  • Greece’s Mandatory myDATA Electronic Reporting: Requires electronic submission of transactional data to tackle VAT fraud and enhance revenue collection efficiency.
  • Italy’s Automated Tax Filing and Payment Systems: Implements digital platforms for tax processes to minimize errors and improve administrative efficiency.