Global Tax Transparency and Minimum Tax Implementation
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Poland: Commits to CARF implementation by 2027, standardizing reporting of crypto-asset transactions for automatic exchange.
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Poland: Draft law proposes 15% minimum tax for MNE groups with €750M+ annual revenue, including IIR and UTPR, effective January 2025.
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Lithuania: Plans full Pillar 2 implementation, including IIR, UTPR, and domestic top-up tax, from January 2025.
Corporate Taxation and Investment Incentives
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Ireland: Budget 2025 introduces Participation Exemption for Foreign Dividends, offering tax-exempt treatment for qualifying dividends from EU/EEA/treaty countries, effective January 2025.
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Brazil: Extends PADIS program to 2029, providing PIS/COFINS, IPI, and import tax exemptions for semiconductor and ICT sectors.
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Malaysia: Exempts qualifying unit trusts from tax on capital gains from disposal of unlisted shares and foreign-sourced income, subject to conditions, until 2026/2028.
Personal Taxation and Social Security Adjustments
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Ireland: Budget 2025 increases standard rate band by €2,000, raises various tax credits, and adjusts USC bands, reducing the 4% rate to 3%.
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Argentina: Sets new monthly social security contribution bases: minimum ARS 82,287.12, maximum ARS 2,674,292.72, effective October 2024.
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Curaçao: Introduces ANG 2,500 tax credit for compliant taxpayers with small tax debts, applicable to various tax liabilities.
Indirect Taxation Strategies
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Cyprus: Ends zero VAT rate on basic goods, meats, and vegetables from October 1, 2024, reverting to pre-decree rates.
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Ireland: Proposes 9% VAT rate for heat pumps and extends 9% rate for gas and electricity to April 2025. VAT registration thresholds to increase to €42,500 for services and €85,000 for goods.
Sector-Specific Fiscal Measures
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Ireland: Introduces 20% tax credit for unscripted productions (max €15M per project) and 8% uplift for feature films under Section 481. R&D tax credit first-year payment threshold increased to €75,000.
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France: Proposes 8.5% temporary contribution on companies with €1B+ annual revenue, increasing effective rate to 33.5%.
Insights:
The global tax landscape is rapidly evolving towards a unified, data-driven approach. As countries rush to implement Pillar 2 and crypto-asset reporting, we’re witnessing the birth of a new era in tax transparency. This shift could fundamentally alter how multinational enterprises operate, potentially leading to more centralized decision-making and standardized global tax strategies.
The tension between attracting investment and ensuring fair taxation is evident in the latest corporate tax measures. Ireland’s participation exemption and Brazil’s tech incentives signal a growing trend of highly targeted tax policies designed to foster specific economic outcomes. This precision approach to tax incentives may become the new norm, replacing broader, less discriminating policies.
