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International Tax Updates

On December 12, 2024 the Taiwan’s Ministry of Finance confirmed that the tax thresholds for small businesses will increase starting January 1, 2025. For businesses selling goods, the monthly tax threshold will rise to NT$100,000 (around US$3,076), while for businesses offering services will be NT$50,000 (about US$1,538). These updated thresholds will apply to the first quarter of 2025.

The Ministry also confirmed that businesses must pay taxes for this period between May 1 and May 10, 2025. The increase in thresholds is intended to support small businesses, and make sure that they have more flexibility to manage their operations.

On December 12, 2024 the Isle of Man Council of Ministers announced that corporate income tax returns for financial periods ending December 31, 2023, will not be treated as late if filed by January 2, 2025. A late filing penalty of £250 (US$315) will apply after this date.

To read more on the announcement, click here.

On December 12, 2024 the Czech Ministry of Finance published online the bulletin concerning monthly tax deadlines for 2025. Specifically, the bulleting supplied with information regarding key filing and payment obligations for VAT, individual income tax, withholding tax, real estate tax, and windfall profits tax. The notice also explains the compliance requirements in accordance with the U.S. Foreign Account Tax Compliance Act (FATCA). Important to mention, the Ministry of Finance in the bulletin covered the country-by-country (CbC) reporting obligations, disclosures for cross-border arrangements, and reporting duties for platform operators. The bulletin provides a comprehensive guide to ensure taxpayers and businesses meet their 2025 compliance deadlines efficiently.

To read more on the tax calendar, click here.

On December 11, 2024 the North Macedonian Assembly accepted for consideration Bill No. 08-6043/1/2024, which proposes changes to VAT regulations. For instance, the bill introduces VAT exemptions for certain services, such as postal services, the rental of certain residential properties, banking and financial transactions, insurance and reinsurance services, and educational services among others. Additionally, it outlines procedures for issuing, transmitting, receiving, and storing electronic invoices. The proposed amendments aim to simplify processes and clarify VAT treatment for key sectors.

To read more on the Bill, click here.

On December 11, 2024 the Colombian National Tax and Customs Directorate announced the 2025 tax calendar and the updated tax value unit (UVT), set at 49,799 pesos (US$11.44). The tax deadlines for 2025 include installments and declarations based on taxpayer type and identification numbers. Natural persons, legal entities, and large taxpayers must submit 2024 tax declarations and installments in February, April, and June. Large taxpayers’ advance income tax installments for 2025 are due in April and June, while other legal entities have deadlines in May and July. Financial institutions must pay advance taxes in May and July as well. Individual income tax returns and payments are due between August and October 2025, while transfer pricing returns must be filed in September. These deadlines ensure organized and timely tax compliance.

On December 9, 2024 the Uruguayan General Directorate of Taxation published the tax calendar for December 2024, announcing key filing and payment deadlines. Minimum VAT payments are due by December 20. Income tax filing and payment for taxpayers under special company control (CEDE) must be completed by December 23, while non-CEDE taxpayers have until December 26 to meet their income tax obligations. These deadlines aim to ensure timely compliance with tax regulations.

To read more on the details of the tax calendar, click here.

On December 6, 2024 the Danish Customs and Tax Administration addressed online the VAT deduction rules for real property purchases. A company planned to buy parcels of land, including several properties and an activity track, with the intention of continuing to rent one property previously leased by the VAT-registered seller. The Tax Council ruled that the property transfer, including the activity track, was VAT-exempt because the rental activity would continue. It further found the VAT charged by the seller invalid since the purchase did not qualify as a business transfer. Consequently, the company could not deduct the VAT.

To read more on the publication, click here.

On December 5, 2024 the Finance Ministry of Republika Srpska proposed amendments to the income tax law, set to take effect on January 1, 2025. The changes aim to clarify definitions, including income from independent and entrepreneurial activities. They introduce the classification of a small entrepreneur, defined as employing no more than three workers and earning under 100,000 Bosnian convertible marks annually. The annual tax for small entrepreneurs would double to 1,200 convertible marks, with some exceptions. A 10 percent withholding tax on income from occasional self-employment by non-residents is also proposed, alongside rules for revoking and reapplying for small entrepreneur status.

On December 5, 2024 the Swedish Official Gazette published Law No. SFS 2024:1207, introducing changes to the special income tax for non-residents, effective January 1, 2025. The law broadens taxable income categories to include salaries, pensions, unemployment benefits, and occupational injury compensation. Board members' compensation will be taxable regardless of where the business operates. Pensions become taxable under specific conditions, with thresholds in place. Maritime income will be taxable for work on Swedish or certain foreign merchant ships, and cross-border work is taxable if foreign work accounts for less than half of the year’s total working time.

To access the Law, click here.

On December 4, 2024 Moldova tax authorities emphasized that by December 26, 2024 latest taxpayers need to proceed with the 2024 wealth tax payments. This tax applies to residential properties and holiday homes with a combined area of at least 120 square meters and an estimated value of 2 million Moldovan lei or more. Payments can be made online using the Mpay platform. Late payments will be liable to a daily penalty of 0.0273 percent of the unpaid amount. Additionally, individuals with electronic signatures can access and generate their 2024 tax payment notices online for the applicable fiscal period.

On December 4, 2024 the Estonian Ministry of Finance proposed new measures to enhance VAT collection. The plan includes eliminating the €1,000 (US$1,058) thresholds for declaring transactions, requiring all invoices to be reported as part of VAT returns. Additionally, the proposal mandates the use of e-invoices, aiming to improve efficiency and ensure greater accuracy in data reporting.

To read more on the public announcement, click here.

On December 3, 2024, Poland approved the draft bill that amends VAT regulations, set to take effect on April 1, 2025. Among the key updates is a zero percent VAT rate for rescue ships and lifeboats used at sea, excluding other seagoing vessels. The bill maintains an 8 percent VAT rate for certain medical devices introduced under earlier legislation and provides clearer guidelines for applying reduced rates on fertilizers, plant protection products, and agricultural goods. It also reduces the VAT on menstrual cups from 23 percent to 5 percent. Additionally, the reverse charge mechanism for gas, electricity, and greenhouse gas emissions trading will be extended until December 31, 2026, with the provision coming into force on February 28, 2025. These changes aim to refine and simplify VAT compliance.

To access the Bill, click here.

On December 3, 2024 Czech Republic published the updated list of the Double Tax Agreements (DTAs) that are currently into force. To access the list, click here.

On December 2, 2024 Bulgaria reviewed a new Bill that proposes changes to the Corporate Income Tax Act. Among the measures proposed, the bill defines the activities that are not eligible for minimum aid tax relief and furthermore introduces updated reporting deadlines for tax periods starting January 1, 2024, through March 31, 2025. In addition, the bill raises the maximum threshold for minimum aid over three years to €300,000 from the previous threshold of €200,000.

The law will take effect on January 1, 2025.

In November 2024, the Albanian Tax Administration announced a new feature on the central fiscalization platform. Taxpayers can now see rejected electronic invoices from buyers directly in their purchase ledger. This update applies to ledger declarations beginning with November 2024, aiming to streamline invoice tracking and enhance transparency in tax reporting.

With this update, buyers no longer need to manually correct the purchase ledger in Excel after the automatic transfer of ledgers to e-filing. Sellers will receive notifications about rejected invoices through the Self-Care portal, making it easier to track and verify them. This ensures that sellers can issue corrected or canceled invoices within the billing period.

To read more on the public announcement, click here.

On November 28, 2024 the Swiss Federal Tax Administration launched a consultation on draft VAT guidelines addressing balance and flat tax rates for industries including motor vehicles, finance, and sports. The draft outlines key provisions, such as exemptions for resold travel services by agencies, an annual accounting period for billing with balance tax rates, and changes to platform taxation requiring electronic notifications from 2027. It also introduces the Simplified Settlement System (SSS), which standardizes billing methods, input tax processes, and tax declarations, while providing transitional rules for adapting billing methods and electronic procedures. The guidelines, set to take effect on January 1, 2025, are open for public comments until December 16, 2024.

On November 28, 2024 the Italian Ministry of Economy and Finance announced an extension for the payment deadline of the second income tax installment. VAT holders with income or compensation that do not exceed €170,000 in the previous year now have until January 16, 2025, instead of the original deadline of December 2, 2024, to make their payments.

To read more on the announcement, click here.

On November 27, 2024 Vietnam's General Department of Taxation issued guidance on tax obligations for selling goods through nonresident digital platforms. Nonresident contractors with a permanent establishment in Vietnam, a business presence exceeding 183 days, and using Vietnamese accounting must directly register, declare, and pay VAT and corporate income tax (CIT). If these conditions are not met, the Vietnamese payer is responsible for handling VAT and CIT on behalf of the nonresident before making payments. Nonresident contractors may choose to declare and pay taxes per payment or monthly for frequent transactions. Taxpayers must submit a tax registration dossier, including a declaration form and contract list, to the relevant tax authority.

On November 27, 2024 Singapore published Law No. 35 of 2024 in the Official Gazette, introducing amendments to the Income Tax Act. Effective from assessment year 2025, the income threshold for deductions will double to S$8,000 (US$5,760). Base tax rates for approved companies will range between 5% and 15%, depending on approval dates relative to February 17, 2024. The law provides tax credits for eligible company expenses and allows recipients of the Manufacturing Singapore Innovation (MSI) Regime to opt for net tonnage-based taxation on qualifying income, replacing exemption benefits. Additionally, the Comptroller may remit taxes or provide cash up to S$40,000 (US$29,830) or 50% of the tax payable for assessment year 2024. Most provisions of the law take effect immediately.

To read more on the Law, click here.

On November 26, 2024 Slovenia published Law No. 3103 in the Official Gazette, amending the Corporate Income Tax Act. The new law removes Article 32, which limited the tax recognition of interest, and raises the threshold for recognizing excess borrowing costs in Article 54c from €1 million (US$1.1 million) to €3 million (US$3.2 million). It also allows taxpayers to reduce their tax base for unused reliefs over five tax periods after the investment period and claim reductions for tax losses from prior periods within the first five tax periods after the law’s implementation. Additionally, it abolishes the special arrangement for determining the tax base using standardized expenses and clarifies the cessation of rights related to tax losses and reliefs. Effective November 27, the amendments apply to tax periods starting on or after January 1, 2024

To read more on the Tax Act, click here.

Italy – Income Tax Payment Deadline Extended to January 2025

As per a presentation by the Finance Ministry, Chile plans to reduce the corporate tax rate from 27% to 25%, against the original proposal by business representatives who had requested a 23% rate. In addition, the prospective Bill will likely include a 16% capital gains tax for certain shareholders and a 4% tax on all dividends, that would result in a total tax burden on corporate profits of approximately 39.5%, just below the OECD average. The changes are expected to be revenue-neutral for the government.

On November 23, 2024 the Slovak Financial Administration published Guide No. 7/DPH/2024/IM, providing FAQs on VAT rates for restaurant and catering services effective January 1, 2025. The guide explains VAT rates, including a 5% reduced rate for food services, a 19% reduced rate for beverages with up to 0.5% alcohol, and a 23% standard rate for beverages exceeding 0.5% alcohol. It also addresses VAT rules for various sectors like restaurants, pizzerias, and hospitality, as well as the taxation of advance payments and entrance fees for New Year’s Eve events spanning midnight. The guide clarifies VAT application for the gastronomic sector.

On November 22, 2024 the Norwegian Tax Administration provided with the Tax Appeals Board decision that explains the withholding tax rules for dividends under the 1971 tax treaty with the U.S. The case involved a U.S.-based regulated investment company seeking a refund after the Tax Office applied a 15% withholding tax rate to 2013 dividends but increased it to 25% for 2014-2016. The Board, following the appeal on the case, decided that the taxpayer was the beneficial owner under Article 8 and eligible for the 15% rate.

To read more on the Board Decision, click here.

The Spanish government has increased the maximum extraordinary tax on the country’s largest banks, raising it to 7% from the previous 4.8%. The new rate applies to banks earning more than €5 billion ($5.2 billion) annually from interest and fee income, targeting institutions like Banco Santander SA and BBVA. The tax extension, approved by Parliament, has faced strong criticism from Spanish banking associations AEB and CECA, who argue it creates legal uncertainty, damages competitiveness, and was implemented without transparency or public dialogue. The governing Socialist party also extended the tax for three more years, surprising analysts with changes to its structure.

On October 22, 2024 the Iceland’s Parliament (Althingi) began reviewing Bill No. 307, proposing changes to tax and fee laws. The bill allows pension funds to hold up to 35% of shares in collective investment funds focused on small or medium-sized companies, provided the total assets per fund don’t exceed 1%. It also grants taxpayers the right to demand late payment interest on refunds of taxes, fees, or fines if they file a court case. Additionally, it exempts the accommodation tax for certain non-VAT accommodations and lodging provided by staff on domestic cruises. If passed, the law would take effect on January 1, 2025.

The North Macedonian Public Revenue Office reminded taxpayers that VAT-04 returns for the previous tax period must be filed by November 25, 2024. Taxpayers are advised to meet the deadline to avoid penalties or possibly extra financial costs. The Tax Agency will be supporting those who will need additional information to complete their filing.

To read more on the public notice, click here.

On November 19, 2024 the Lithuanian State Tax Inspectorate opened a consultation on proposed changes to the VAT Law, specifically Article 42. The draft amendment clarifies that a 0% VAT rate applies to goods purchased by passengers who transport them out of the EU. Nonresident passengers seeking VAT refunds must provide merchants with identification and proof of non-EU residence when purchasing goods. The amendment also details VAT refund procedures and conditions for refund eligibility. It outlines that a single document may establish permanent residence but can be supported by additional evidence. Public comments on the draft are being accepted until December 3, 2024.

On November 19, 2024 Sweden raised the taxable income threshold to 625,800 kronor (US$56,988). The new threshold will be effective as of January 1, 2025.

Click here to read on the Regulation amending the income threshold.

On November 18, 2024 the Austrian Federal Ministry of Finance published a Federal Finance Court decision clarifying rules on capital gains from hidden profit distributions. The case involved a company purchasing another’s assets and liabilities, where the taxpayer was a key figure in both companies. The Tax Office assessed capital gains tax, which the taxpayer contested unsuccessfully. The court upheld the Tax Office’s decision, finding the transaction was not at arm’s length. The purchaser waived payment, inventory descriptions were vague, and provisions for guarantees matched the acquired assets, suggesting implausible terms for unrelated parties. The court emphasized the taxpayer’s decisive influence over the companies, confirming the Tax Office’s assessment.

To learn more on the matter, click here.

On November 15, 2024 the Norwegian Ministry of Finance opened a consultation on new disclosure rules under EU Directive 2023/2226 and the Crypto-Asset Reporting Framework. The proposal expands reporting requirements for crypto-asset service providers, obligating them to disclose user data, including stored crypto values in official currency, regardless of tax residency. Nonresident providers must meet similar obligations, except for foreign storage services. Providers must identify all users, including rights holders, to establish tax residency. In addition, the rules also extend automatic information exchange to digital assets and central bank digital currencies. Comments are due by February 15.

To read more on the specifics of the consultation, click here.

On November 13, 2024 the Mexico's Tax Administration Services introduced a new tax regime to support welfare programs and strengthen Pemex’s finances. The Oil Right for Welfare regime sets a 30% tax on oil and 11.63% on non-associated gas. Austerity measures aim to save 50 billion pesos by reducing Pemex subsidiaries and improving efficiency to address its debt. The plan also promotes mixed public-private projects while keeping control of energy resources, expands renewable energy production for domestic use, and boosts oil and natural gas output. Additionally, it seeks to enhance refining capacity and lower dependence on imported gasoline and diesel.

To read more on the new tax regime, click here.

On November 13, 2024 the Brazil’s Federal Revenue Office announced an updated version of the digital tax bookkeeping system, ECF 10.0.14, designed for reporting corporate income taxes (IRPJ) and social contributions on net income (CSLL). This update brings key improvements, including fixes to validation rules in the 2019 and 2020 layouts, corrections to RTF file imports for the Y800 record, and adjustments to editing and creating the 0020 record. Errors in tab reports and folder generation were also resolved, and a new installer with a signature was introduced. The updated system supports filing ECFs for the 2023 calendar year, special 2024 cases, and both original and amended filings for earlier years.

To read more on the specifics of the bookkeeping system, click here.

On November 12, 2024 the Estonian Parliament (Riigikogu) agreed to consider Bill No. 539 SE, which proposes reducing the VAT rate from 22 percent to 5 percent. The reduced rate would apply to physical and electronic press publications, with certain restrictions, as well as to food products, including items like potatoes, fruits, and vegetables. This initiative aims to make essential goods and information more affordable for consumers.

To access the Bill, click here.

On November 12, 2024 the Lithuanian Tax Authority opened a consultation about some changes to the Individual Income Tax Law. The proposal aims to regulate expenses’ deduction policies for permanent residents. For instance, starting in 2025 the new rules propose that life insurance premiums to be deducted from annual income if the insurance contract was signed before December 31, 2024, and payments are made by December 31, 2034. Residents can submit their comments on the draft changes until November 20, 2024.

To access the draft, click here.

On November 12, the European Commission updated VAT rules for small enterprises, that will take effect on January 1, 2025. These rules allow small businesses to sell goods and services without charging VAT, hence reducing their compliance burdens. The maximum national annual threshold for VAT exemptions is set at €85,000, while small enterprises with an annual turnover across Member States under €100,000 can also qualify for cross-border VAT exemptions. Additionally, the rules clarify that businesses established in one Member State can exempt cross-border supplies in the same way as local enterprises. These changes aim to simplify VAT processes for small businesses across the EU.

To read more on the new rules, click here.

On October 7, 2024 the Norwegian Tax Administration published a decision by the Tax Appeals Board on the taxation of dividends and share sales gains. A Norwegian resident shareholder received extraordinary dividends, but the Tax Office found errors in the entry value’s calculation, as the dividends weren’t deducted. This led to a 20% additional tax on increased income. The taxpayer appealed, citing the complexity of the rules and the time elapsed since the error. The Board partially upheld the appeal, ruling that the error was understandable and made in good faith, and excused the taxpayer’s failure to provide correct information, removing the additional tax.

Click here to learn more on the Board’s Decision-making.

On November 6, 2024 the Swedish Tax Court issued Advance Notice No. 32-24/D, clarifying the tax liability of foreign citizens leaving Sweden. The case involved a taxpayer who lived in Sweden briefly from 2005 to 2006 and again starting in 2022, before planning to move to Great Britain. His only connection to Sweden after the move would be his partial ownership of, and board membership in, a company operating there. The Tax Agency argued this constituted a substantial connection under the Income Tax Act. However, the court ruled that despite his influence on the company, his limited time in Sweden and foreign citizenship meant he wouldn’t have unlimited tax liability after moving.

To access the content of the Notice, click here.

On November 6, 2024 the Slovak Parliament agreed to consider Bill No. 588, which proposes repealing the financial transaction tax (FTT) established under Law No. 279/2024. The FTT, set to begin in January 2025, includes rates of 0.4% for non-cash transfers, capped at €40, 0.8% for ATM withdrawals, and €2 for payment card use. If passed, the repeal would take effect on March 1, 2025.

On November 5, 2024 the Maldivian Inland Revenue Authority announced that the President ratified three amendments: the Goods and Services Tax (GST) Act, Maldives Tourism Act, and Airport Taxes and Fees (ATF) Act. Key changes include an increase in the tourism sector GST to 17% from July 1, 2025, while an 8% GST rate applies to certain employee-only cafes from November 5, 2024. New departure tax and airport development fees start December 1, 2024, with refunds available for excess tax collected. Green tax changes, effective January 1, 2025, exempt children under two. The amended laws take effect immediately upon ratification.

To read more on the amendments, click here.

On October 31, 2024 the Uruguayan Official Gazette published Decree No. 281, introducing temporary tax incentives for telecommunications companies investing in electronic surveillance services for criminal investigations by June 30, 2025. The incentives cover electronic data processing equipment and related software but exclude costs for maintenance, updates, and replacements. Companies can exempt 100% of qualifying investments, up to 12 million indexed units, from income tax on economic activities. Additionally, covered assets are exempt from wealth tax for their useful life. The decree took effect immediately upon publication, aiming to support technological advancements in criminal investigations.

To read more on the Decree, click here.

On October 30, 2024 the New Zealand’s Inland Revenue started a consultation on new guidelines which aim to make tax residency rule clearer, as provisioned under Income Tax Act 2007. For instance, the guidelines explain who qualifies as a tax resident, be that an individual or company. For individuals, they cover tests like the place someone lives most of the time and how many days they spend in New Zealand. For companies, they look at where a company is run or based. For trusts, they explain how trustee and beneficiary income is taxed. Furthermore, the guidelines also address how Double Tax Agreements can resolve dual residency issues, what happens to taxes when residency changes, and special tax breaks for new migrants. Feedback is open until December 11,2024.

On October 30, 2024 the Latvian Parliament supported Bill No.742, which proposes changes to the personal income tax, as part of the 2025 public budget. The new changes introduce a single, fixed nontaxable minimum for all salaries, regardless of income. This fixed amount will be €510 monthly in 2025, and it will grow up to €550 in 2026, and €570 in 2027. In addition, the pensioners’ nontaxable minimum will be doubled, reaching a €1,000 per month. If passed, the law will take effect on January 1, 2025.

To read more on the specifics of the Bill, click here.

Tax Authority in Georgia, the Revenue Service, clarified that the deadline to submit the 2024 annual property tax return is November 15, 2024.

To read more on the announcement, click here.

The Tax Authority in Cyprus has extended the deadline to submit 2023 individual tax statements. The new deadline is November 30, 2024.

To learn more on the notification, click here.

As of 2024 it is estimated that only 6% of estates will be subject to inheritance tax in 2024. Pursuant to the tax laws, the primary £325,000 of a property is exempt from inheritance tax, increasing to £500,000 if it includes a home inherited to direct descendants. For married couples or civil partners, the tax-free threshold can reach £1 million if allowances are transferred to a surviving spouse or partner.

On October 29, 2024 the Swedish Official Gazette announced Law No. SFS 2024:942, which changes the VAT Act. The law makes several important updates. It defines who is considered a taxable person and what transactions are taxable. Small businesses earning under 120,000 Swedish kronor (about $11,279) in Sweden or 100,000 kronor ($9,398) in the EU will not have to pay VAT. It also exempts some transactions, like intra-Union deliveries and exports, and sets a 12% tax on certain artworks and antiques. Additionally, the law explains how to deduct input tax and outlines the process for handling exemptions and appeals. These changes will take effect on January 1, 2025.

To access the text of the law, click here.

On October 29, 2024 the Swiss Federal Tax Administration published updated guidance on federal withholding tax, effective January 1. This guidance includes important information on several topics. It covers income tax withholding and raises the default interest rate for VAT from 4% to 4.75%. It also discusses income from movable capital assets, tax debtors, and rates for claims and refunds. The guidance addresses tax evasion and penalties, as well as procedures and regulations. Lastly, it lists types of income that are exempt from tax.

To read more on the content of the Guidance, click here.

On October 28, 2024 the Polish President signed a new law amending the Personal Income Tax Act, and is now expected to enter into force on January 1, 2025. The new changes include tax exemptions and simplified rules. For instance, under the new law, seafarers who are EU nationals in the European Economic Area (EEA) will be exempt from income tax. Additionally, a flat tax rate will now apply to income relief on inherited company income, and tax exemptions will cover benefits received from capital funds. Another key change is that business owners with flat-rate income will have access to new, simplified personal income tax (PIT) options. These updates aim to provide more flexible tax benefits and reliefs for Polish and EU taxpayers.

To read more on the changes in the law, click here.

Liechtenstein's Official Gazette published Law No. 641.20 on October 29, 2024 amending the VAT Act with new measures effective January 1, 2025. Key updates include: VAT now applies to domestic services purchased from nonresidents and on the acquisition of emission rights; clarified place-of-supply rules for resold travel and on-site services like cultural and sporting events; criteria for when electronic platform operators are VAT-liable service providers; a list of VAT-exempt goods and services, including certain gold transactions; and a reduced VAT rate of 2.6% for menstrual hygiene products.

To learn more on the Law, click here.

On October 28, 2024 the Slovak Financial Administration released Guide No. 13/PO/2024/IM, detailing the reinstated minimum tax for legal entities effective January 1, 2024. The guide outlines progressive flat rates starting at €340 for taxable income up to €50,000 and reaching €3,840 for incomes over €500,000. It includes information on minimum tax due dates and credits, payment processes for those changing their taxation period, and rules for entities dissolved without liquidation. Additionally, a 50% minimum tax reduction is available for companies with at least 20% of registered employees with disabilities. Calculation examples are also provided.

You can access the Guide, by clicking here.

On October 28, 2024 the Malta’s Ministry of Finance presented the 2025 budget, bringing in updates to wages, taxes, and housing incentives. The minimum weekly wage will increase slightly, and income tax brackets will be adjusted, with a maximum rate of 35%. Pensioners will benefit from more nontaxable income. Support continues for homebuyers, with extended stamp duty reductions, as well as tax relief for family-owned business transfers. For electric and hybrid vehicles, registration tax exemptions will continue. There will also be no VAT on certain sanitary products and cancer treatment accessories. Finally, incentives to restore heritage properties will stay, with capital gains tax and VAT savings available on qualifying property and restoration costs.

To learn more on new changes, you can access the 2025 Budget Draft here.

On October 26, 2024 the Uruguayan Tax Office clarified that the deadline to proceed with the payment of the primary tax’ last installment is October 31st, 2024. Taxpayers are advised to make the payments either via collection networks or online.

To read more on the specifics of the announcement, click here.

The Lithuanian State Tax Inspectorate has updated its guidance for Article 115 of the VAT Law, detailing a special VAT regime for services provided by non-EU businesses to EU consumers. Key points include: non-EU service providers can use the regime for EU-based clients, provided they don’t have a permanent establishment within the EU. The update also outlines registration and deregistration rules, clarifying that non-EU businesses can register as VAT payers in Lithuania, regardless of prior status. Registration for this regime can be completed through the One-Stop-Shop (OSS), where quarterly electronic returns are also required.

To read more on the details of the amendments, click here.

In October 2024 the Cyprus Tax Department extended deadlines for submitting income tax declarations for 2022 and 2023. This extension applies specifically to taxpayers who must submit a Summary Table of Information on Controlled Transactions. The new time limits now are due by February 28, 2025, for the 2022 income tax filings and November 30, 2025, for the 2023 filings. These extensions provide taxpayers with extra time to prepare and file their required documentation.

To read more on the new deadlines, click here.

On October 25, 2025 the Dutch Tax and Customs Administration has announced several changes to VAT rules, set to, take effect on January 1, 2025. Among these updates, the VAT rate for specific agricultural goods will increase from 9% to 21%, impacting the agricultural sector. New rules will also apply to virtual services, which will now be taxed in the customer's country. For dealers of antiques, art, and collectibles, the special margin regime will end, though unsold items will still qualify for input tax deductions through early 2025. Additionally, service charges imposed by real estate lessors will see adjusted tax treatment, while modifications to the small business regime (KOR) and the introduction of the EU-KOR will provide VAT exemptions across multiple EU countries.

To read more on the details of the notification, click here.

On October 18, 2024 the Lithuania’s State Tax Inspectorate began a public consultation on proposed updates to Article 2 of the Corporate Income Tax Act, focused on defining permanent establishments (PEs). The amendments aim to clarify the PE definition, explain its application under Double Tax Agreements, the OECD Model Convention, and the Multilateral Instrument (MLI). Key points include the OECD’s criteria for a PE, such as conducting economic activities in another country for at least six months or completing them fully, and establishing a PE through services provided in Lithuania for over 183 days in 12 months. Comments are open until October 25, 2024.

To access the details of the Draft, click here.

The Albanian Tax Administration has extended the deadline for submitting ownership certificates and lease contracts through the e-Filing procedure to November 20, 2024. This applies to both main and secondary addresses and is essential for accurate Withholding Tax calculations and pre-filled personal income declarations. Missing the deadline will be considered an administrative offense under domestic law.

To read more on the extended deadline specifics, click here.

On October 25, Poland provided with the updated EU’s list of non-cooperative tax jurisdictions. This list, distinct from jurisdictions known for harmful tax competition practices, now includes American Samoa, Fiji, Guam, Palau, Russia and Trinidad and Tobago.

To access the official announcement, click here.

Germany’s finalized withholding formula for December 2024, released by the finance ministry on October 18, incorporates recent updates from the draft Act on the Tax Exemption for the Subsistence Minimum 2024, though the act is yet to be passed. This new formula reflects an increase in the tax-free income threshold from €11,604 to €11,784, along with a rise in the child allowance from €6,384 to €6,612 per year (€3,306 per parent). These changes, retroactive to January 1, 2024, apply to pay periods beginning after November 30 and ending before January 1, 2025.

On October 22, 2024, the Serbian Tax Administration announced that October 30, 2024 is the deadline for individuals under self-taxation. Those who earned freelance income from copyrights or related rights in Quarter 3 of 2024 must submit their tax returns and pay the tax by this date. Filers can use the ePorezi portal or the Freelancers portal for submission.

To read more on the specifics of the tax filings, click here.

On October 18, 2024, the President of Slovakia signed the new tax law, which is set to enter into force on November 30, introducing several important changes. Small businesses with a turnover of around €100,000 will now see their corporate tax rate reduced from 15% to 10%. The tax break for entrepreneurs and small businesses has been increased to €100,000. Larger companies earning more than €1 million will face an additional tax rate of 22%. The bill also makes changes to child tax benefits, removing compensation for dependents over the age of 18. In addition, the normal VAT rate increases to 23%, while at a reduced rate 19% for essentials like food and energy, and 5% for medicines also come.

To read more on the Bill, click here.

On October 18, 2024 the North Macedonia's Public Revenue Office confirmed that October 25, 2024 is the deadline to file VAT-04 returns. However, the Tax Authority emphasized that even in the cases of no taxable turnover, taxpayers need to proceed with the filing, so that they meet the legal obligations.

To read more on the announcement, click here.

On October 2024, the Federal Supreme Court in Brazil ruled that applying a 25% withholding income tax on retirement and pension income paid to individuals living abroad is unconstitutional. As a result, part of the received pensions and retirements from Brazil by non-residents will be exempt, in line with the exemptions already available to Brazilian residents.

The Court, while examining the provisions under Article 7 of Law No. 9,779/99, as amended by Law No. 13,315/16, further emphasized that taxing foreign residents differently from domestic residents violates the principles of Equality, Progressiveness of Income Tax, and Proportionality as enshrined in the Federal Constitution.

More details can be found in the official ruling here.

On October 18, 2024 the Argentina’s Ministry of Economy requested the Federal Administration of Public Revenue to extend the deadline for taxpayers to join the Special Regime of Income Tax on Personal Property (hereinafter REIBP). The extension allows two groups until October 31, 2024 to complete the process:

  1. Taxpayers who started joining REIBP by September 30, 2024 but couldn’t finish, and
  2. Taxpayers who filed their personal property tax return by September 30, 2024 and now want to join REIBP.

The voluntary program allows individuals to pay taxes in a unified way until December 31, 2027, covering assets regularized under Law No. 27743/2024.

To read more on the extended deadline specifics, click here.

On October 17, 2024 the Belgium’s Federal Public Service-Finance confirmed that an extension for submitting withholding tax returns (hereinafter WTH) has been provided. According to the announcement, given the technical problems the new deadline now is October 30, 2024. The new deadline concerns WTH for September 2024 and the third quarter of 2024 However, interest on late payments will apply only from October 31, 2024.

To read more on the announcement, click here.

On October 16, 2024, the Swiss Federal Assembly approved the draft law providing for an increase in VAT rates, to be implemented from January 2026. The changes include:

  • Increasing the fixed rate of VAT from 8.1% to 8.8%.
  • Increasing the special VAT rate on construction services from 3.8% to 4.2%.
  • Revised VAT rate reduction from 2.6% to 2.8%.

These changes are part of the council’s plans to implement new tax policies in the coming years. Click here to read more on the specifics of the VAT rate increase.

On October 15, 2024 the Moldavian State Tax Service published an online calendar announcing key tax deadlines for October 2024. According to the announcement, October 25, 2024 it is an important deadline that applies to:

  • Taxpayers who must pay taxes, fees, compulsory health insurance premiums, and social security contributions for August 2024.
  • By this date tax returns for September 2024 must be filed.
  • Income taxes for small and medium-sized businesses for the third quarter of 2024 need to be paid.

To read more on the deadlines for tax submissions, click here.

On October 14, 2024 the Lithuanian State Tax Inspectorate announced the new changes to the VAT refund policy for goods bought in Lithuania and exported by non-EU residents. According to the new rules, intermediaries must now provide sellers with a digital copy of the printed declaration, stamped by customs to confirm the goods’ export from the EU. This declaration, submitted by the foreign buyer, is the basis for the VAT refund. Additionally, intermediaries are required to keep the printed declaration for 10 years. These changes came into effect on September 28, 2024.

On October 10, 2024 the New Zealand Inland Revenue issued a Technical Decision Summary clarifying tax rules for restructured group taxation. Shareholders wanted to switch from a holding company structure, which held long-term investments, to a limited partnership. Their goal was to access capital gains without liquidating the holding company.

The Tax Counsel Office confirmed that: 1) removing the holding company from the New Zealand Register is considered liquidation under the Companies Act; 2) liquidation began when shareholders agreed to the amalgamation proposal; 3) the arrangement aligns with the Income Tax Act's rules on dividends and liquidation; and 4) it doesn’t offer any unfair tax advantage or allow artificial changes to retained earnings.

To access the tax rules for restructures group taxation, click here.

The American tax authority, the IRS, has informed the Israeli Tax Authority that it has issued a notice stating that Israeli residents who report to U.S. tax authorities will receive an extension until September 30, 2025, for the submission of their annual reports for the years 2023 and 2024, as well as for making payments and performing other actions required between October 7, 2024, and September 30, 2025.

On October 9, 2024 Austria introduced tax relief measures for 2025 under Law No. 144. Key changes include: higher income tax bracket thresholds (except the top one); an increase in the monthly child tax credit to €60 for single low-income parents; and a new small business revenue threshold of €55,000 for sales and income tax. Additionally, a mileage allowance of €0.50 per kilometer for vehicles and increased daily (€30) and overnight (€17) business trip allowances are now provided.

To read more on the measures introduced, click here.

On October 7, 2024 the Swedish Tax Agency updated its guidance to align with a recent European Court of Justice (ECJ) ruling on the deductibility of input VAT for goods or services used in ways other than originally planned. The new guidance emphasizes that actual use is more important than intent. For example, input VAT paid for consulting services related to a market survey intended for acquiring shares in another company is deductible, even if the acquisition doesn’t happen, as long as it is connected to economic activity. However, VAT paid on loan payments is not deductible if the intended investments were not made, and the loan amount is fully paid to the group's parent company.

To read more on the new rules, click here.

On October 7, 2024 the Norwegian Ministry of Finance unveiled its proposed tax changes for 2025. Among the key measures is an increase in the maximum tax deduction for pension income, raising it to 35,600 kroner from 34,350. Commuters will also see a slight boost in their deduction, with the rate per kilometer increasing to 1.83 kroner. The social security contribution rate will be reduced slightly for both wages and business income. Additionally, the ground rent tax on wind and hydropower will remain in place. The maximum individual tax rate on wages will stay at 47.4 percent, while the marginal tax rate on pension income will rise slightly. The 25% withholding tax for nonresident workers will also continue.

To read more about the proposed tax changes, click here.

On October 7, 2024, the Latvian Ministry of Finance provided a draft bill that aims to update the VAT Law, and it is expected to enter into force by January 1, 2025. The bill proposes several changes, including VAT exemptions for small and medium businesses involved in cross-border trade within the EU, amounting up to €100,000. Another significant change is shifting how the VAT registration threshold is calculated, moving from a 12-month period to a calendar year. In addition, Small and Medium Enterprises (SMEs) exceeding the threshold in 2024 will need to register for VAT, and a transitional period will be provided for businesses affected by these changes.

To read more on the proposed changes, click here.

On October 4, 2024, the European Court of Justice (ECJ) ruled on Romanian VAT deduction rights in Case C-475/23. An Austria-based company, producing molded parts in Romania, was denied a VAT deduction by the tax authority for using its crane in the manufacturing process. The ECJ clarified that under EU law (Directive 2006/112/EC), the company is entitled to the deduction if the crane was essential for processing the parts. This ruling sets a precedent for future cases, establishing that failure to maintain separate accounts does not justify denying a VAT deduction, as long as the transaction fulfills the substantive legal requirements.

To access the ECJ Ruling, click here.

On October 4, 2024, the European Court of Justice (ECJ) gave a preliminary ruling on Croatian VAT rules. The case involved a Croatian restaurant accused of being set up as a fake company to help another business wrongfully benefit from VAT exemptions meant for small businesses.

Croatian courts argued that their constitution doesn't allow retroactive application of the VAT abuse provisions. However, they asked the ECJ for guidance on whether EU principles on abusive practices could apply. The ECJ ruled that, under EU law (Directive 2006/112/EC), companies formed for abusive purposes cannot continue benefiting from the VAT exemption, even if local laws don’t explicitly prohibit such abuse.

To read the ECJ Ruling, click here.

On October 4, 2024 the Swiss Official Gazette announced Ordinance No. RO 2024 535, which will lower interest rates for late, refunded, and advance tax payments starting January 1, 2025. The new rates will be set at 4.5%, down from 4.75% for defaults, refunds, and conditional payment obligations. Additionally, the interest rate for advance payments will decrease to 0.75% from 1.25%. These changes will apply to various taxes, including VAT, direct federal tax, withholding tax, CO2 levy, stamp duty, and the extra tax for the minimum taxation of large multinational enterprise groups.

Click here to access the announcement.

On October 3, 2024 the Sri Lankan Inland Revenue announced income tax filing deadlines for the 2023-2024 financial year. Registered taxpayers are required to submit their income tax returns by November 30, 2024. Furthermore, the announcement clarifies that electronic filing has become mandatory for individual income tax, partnership income tax, and corporate income tax returns. Taxpayers are advised to start filing individual and partnership returns online through e-services starting now.

As of October 10, 2024 the electronic filing will also be available for corporate income tax returns and simplified income returns for individuals with only primary employment or interest income. To file electronically, individuals need a personal identification number (PIN), while entities and partnerships require both a PIN and a special staff identity number (SSID).

To read more about the announcement, click here.

On October 3, 2024 the Philippine Official Gazette made public Republic Act No. 12023, which will become effective from October 18, 2024.  This law introduces VAT for digital services provided in the Philippines, applying to both resident and nonresident providers. It sets a 12% VAT on digital services used in the country and a 5% VAT for nonresident digital service providers offering services to the government.

According to the new rules, the nonresident service providers with annual sales exceeding 3 million pesos must register for VAT. In addition, they are also required to appoint a local corporation for tax compliance or otherwise will face suspension.

To access and learn more on the details of the Republic Act, click here.

Upcoming changes are expected to impact the EU’s non-cooperative jurisdiction list. On October 8, 2024 the EU finance ministers will vote to remove Antigua and Barbuda from the blacklist, shifting it to the greylist. The greylist includes countries that do not yet fully comply with international tax standards but have committed to reforms. Armenia and Malaysia are expected to be removed from the greylist altogether, signaling their progress in meeting tax governance criteria.

The blacklist, which includes countries that have either failed to meet EU tax standards within a given timeframe or refused to comply, currently features several nations:

  • Caribbean and Pacific Island nations: Trinidad and Tobago, Fiji, US Virgin Islands.
  • Other countries: Panama, Russia.

These updates reflect ongoing changes to the EU’s approach to enforcing global tax compliance and governance reforms across various jurisdictions.

To access the current updated EU non-cooperative jurisdictions list, click here.

On October 2, 2024 the Danish Parliament moved forward with Bill No. L 28, proposing changes to various tax laws for both companies and individuals. Important amendments proposed include: exempting companies from income tax on dividends from unlisted portfolio shares, gradually increasing the cap for share savings accounts starting in 2025, and allowing companies to choose capital gains taxation for up to seven years after listing.

In addition, the bill also raises the personal share income tax threshold from 63,300 to 83,100 kroner, increases the R&D tax credit cap to 35 million kroner starting in 2027, and adjusts rules for carrying forward losses. The law is set to take effect on January 1, 2025, excluding the Faroe Islands and Greenland.

To read more on the amendments proposed in the Bill, click here.

On October 1, 2024, the Irish Department of Finance announced the budget for 2025, which includes several changes to taxes. Here are some of the important updates:

  • The income tax standard rate will increase by €2,000, and individual, employee, and earned income tax credits will rise to €2,000 from €1,875.
  • The 2% Universal Social Charge (USC) rate limit will be raised to €27,382, while the 4% USC rate will be lowered to 3% for incomes between €27,382 and €70,044, starting January 1, 2025.
  • The threshold for the Research and Development (R&D) tax credit will increase to €75,000 from €50,000.
  • VAT registration thresholds will rise to €85,000 for goods and €42,500 for services.

To read on all the tax information, you can access the 2025 Budget here.

On October 1, 2024 the Austrian Federal Ministry of Finance published a Federal Finance Court decision following the case of a taxpayer with two residences claiming business travel expense deductions. The decision provides with new rules affecting taxpayers with two residences, who are now allowed to deduct business travel expenses under certain conditions. To qualify:

  • The travel must be for professional purposes, with sufficient documentation.
  • The distance between the taxpayer’s farther residence and the work site must be reasonable.

If complete documentation of travel is not provided, an estimated deduction can be claimed at a rate of €0.42 per kilometer. This ruling clarifies that, even with incomplete records, taxpayers may still claim deductions, provided the professional nature of the travel is demonstrated.

To access the Federal Finance Court Decision, click here.

Since October 1, 2024 the Royal Decree No. 790 has taken effect in Thailand. This decree extends the temporary VAT rate reduction to 6.3% until September 30, 2025, pushing back the previous deadline of September 30, 2024. The lower rate will apply to VAT liabilities incurred from October 1, 2017, through September 30, 2025.

To read more on the details of the announcement, click here.

On September 30, 2024 the Azerbaijani Ministry of Taxes announced several tax deadlines that are due by October 2024. Some of the main deadlines include:

By October 15, 2024: Deadline for Quarter 3 profit and income taxes, state social insurance fees, unemployment insurance premiums, and compulsory health insurance fees.

By October 21, 2024: Deadline for quarterly income tax for special notaries, September withholding tax on salaries, and tax on early insurance contract terminations.

By October 21, 2024: Deadline to file VAT declarations, road tax, simplified tax on real estate transactions, and cash withdrawals for September.

By October 21, 2024: Deadline to declare and pay September’s mining tax.

To read more on specific details regarding the tax deadlines, you can access the Tax Authority’s announcement by clicking here.

The Croatian Ministry of Finance opened a consultation on September 25, 2024, regarding changes to the VAT law that are planned to take effect on January 1, 2025. Key proposals include increasing the VAT registration threshold from €40,000 to €50,000 and allowing VAT exemptions for businesses with turnover under €50,000 in Croatia or €100,000 in the EU. Another change would remove the requirement for VAT refund reciprocity for non-EU businesses. The deadline to submit comments is October 24, 2024.

To read more about the proposed changes on the VAT law, click here.

On September 25, 2024, South Korea's National Assembly considered Bill No. 2204256, which aims to update the Income Tax Act to provide more benefits for families with children as part of the 2025 tax budget.

Among the several new rules proposed, the Bill includes the increase of the annual income tax credits for residents with children aged 8 or older. For instance, for one child the credit will increase from 150,000 won ($112) to 300,000 won ($224). For two children, it will rise from 350,000 won ($262) to 600,000 won ($448), and for each additional child, from 650,000 won ($487) to 900,000 won ($674).

The changes are expected to take effect on January 1, 2025.

To read more on the details of the Bill, click here.

On September 24, 2024, the tax authority in Estonia clarified that October 1, 2024, is the deadline to pay any additional individual income tax owed based on 2023 income declarations. The accouchement further explains that the taxpayers who may have trouble making their payment on time can schedule a payment vis-à-vis the tax agency’s e-services platform, e-MTA. The platform also allows taxpayers to check the exact amount of income tax they owe.

To read more on the specifics of the communication click here.

On September 24, 2024 the Italian Revenue Agency announced the tax filing and payment deadlines for October 2024. Among the several dates provided, the announcement includes:

By 16 October 2024 taxpayers must pay individual income tax installments for the end of 2023 and the first advance for 2024. This deadline also includes VAT for the previous month and other taxes.

By 31 October 2024 payments for VAT, registration tax, and stamp duty are due, along with corporate income tax declarations and forms for tax substitutes and intermediaries for 2023.

On September 24, 2024 the Bulgarian Tax Authority reminded taxpayers that they need to submit corrective income tax returns by latest 30 September 2024. This deadline applies for individuals who have either undeclared or incorrectly declared their 2023 income. To help taxpayers, government has provided additional information through a podcast episode, the NRA website, or by phone.

To read more on the specifics of the deadline, click here.

On September 23, 2024 the Uruguayan Official Gazette announced Decree No. 256, extending the 9% reduced VAT rate for the tourism sector. Originally set to expire on September 30, 2024, the reduced rate will now be in effect until April 30, 2025. The extension applies only if payments are made through certain electronic methods.

To access the Decree, click here.

On September 20, 2024 the Belgium’s Federal Public Service-Finance announced that it is extending deadlines for filing corporate and individual income tax returns due to technical issues. The new deadlines are:

October 7, 2024 instead of September 30, for corporate tax returns of legal entities and nonresident companies.

October 28,2024 instead of October 16, for individual income tax returns related to certain types of income, including nonresident professional income and first-time declared income.

To read more about the details of the new set dates, click here.

On September 19, 2024, the Swiss Federal Tax Administration published the interest rates for late, refunded, and advance taxes that will apply from January 2025. Among the several interest rates introduced, the announcement confirmed that the interest rate for defaults, refunds, and conditional payments will be lowered from 4.75% to 4.5%.

In addition, the rate for voluntary advance payments will decrease to 0.75%, from the original rate of 1.25%. These rates will apply to a range of taxes, such as VAT, direct federal tax, withholding tax, CO2 levy, stamp duty, and the additional tax for large multinational companies.

To learn more about these new interest rates, click here.

On September 18,2024 the Bulgaria's Ministry of Finance opened a consultation on proposed amendments to the VAT Law. The changes aim to align with EU regulations, and key updates include requiring Bulgarian businesses to register for VAT if their annual turnover exceeds 166,000 Bulgarian leva (around $94,667). In addition, EU businesses must register if they surpass the same threshold in Bulgaria or €100,000 (about $111,538) within the EU. The bill also adjusts VAT rules for internet streaming and virtual events, import VAT procedures for investment projects, and addresses an EU court decision on taxable turnover for second-hand goods and tourism services. The changes would take effect on January 1, 2025.

On September 18, 2024 the Montenegrin Government published a law amending the Personal Income Tax rules. The updated law will now include individual income from internet and video gaming, as well as games of chance, in taxable income. Taxpayers can also deduct 15% of their expenses related to internet activities.

Additionally, income from liquidation distributions that exceed the invested capital will be classified as capital income. The amendments exempt employer benefits for female employees on International Women’s Day, up to 100 euros annually. Furthermore, the exemption limit for food allowances provided by sports clubs to amateur athletes will increase from 300 euros to 600 euros monthly. Lastly, up to 3% of health expenses paid to certain organizations will be recognized.

To read more on the new amendments, click here.

On September 17, 2024, HM Revenue and Customs in the United Kingdom released updated guidance for nonresident companies that conduct business in the UK through a dependent agent permanent establishment (DAPE). The key points include that these companies must register for UK corporate tax within three months of becoming liable for it. The guidance also outlines the necessary documents for registration, the procedures for registering online and by other means, and the obligations companies must follow after they register.

To read more on the specifics of the communication click here.

On September 17, 2024 the Ministry of Finance in Netherland presented the 2025 Tax Plan, that provides with several tax changes. Key amendments include the drop of the income tax rate to 35.82% from 36.97% for income up to €38,441, while a new 37.48% rate will apply to income between €38,441 and €76,817.

Furthermore, the new rules also propose raising the corporate interest deduction limit from 20% to 25%, while reducing the SME profit exemption to 12.7%. In addition, a 27% expatriate tax deduction will remain for five years starting in 2027. VAT on accommodation and cultural services will rise to 21% in 2026, and a dividend tax exemption for listed companies will continue.

To read more on these changes and the other ones, you can access the official announcement here.

On September 16, 2024 Greece's Official Gazette published Law No. 5135, which addresses digital transaction fees and stamp duty. The law repeals stamp duty provisions starting January 1, 2025, and introduces new digital transaction fees of up to 3.6% on certain transactions.

According to the new rules, the transactions made on or before November 30, 2024, will still include the stamp duty. The law also outlines the procedure for paying digital transaction fees and how to calculate these fees for deposits and withdrawals, along with details on exempt transactions.

On September 13, 2024 the Maltese Official Gazette published Legal Notice No. 229 of 2024, which updates the rules on capital expenditure deductions for intellectual property (IP) and IP rights. The changes include defining "qualifying income" as taxable income generated from IP or IP rights, before deductions. The amendments also clarify how to calculate capital expense deductions, noting that for those deductions that can't be fully used due to low income, will be carried forward to future years. Expenses taking place prior to 2024 will be processed using a special calculation method.

To read more on the Legal Notice and access the details of the new rules, click here.

On September 13, 2024, the Maltese Official Gazette published Legal Notice No. 229/ 2024. It updates the rules for deductions related to intellectual property (IP) and IP rights. The amendments define "qualifying income" as the taxable income generated from IP or IP rights before any deductions. In addition, it also clarifies how to calculate capital expense and clarifies that if deductions cannot be used due to insufficient offsetting income, they can be carried forward to future tax years. These changes will apply starting with the 2024 assessment year.

More information on the updated rules, can be accessed here.

On September 13, 2024 the Organization for Economic Cooperation and Development (OECD) published online the updated list of countries that have signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI).

To access the list reflecting the latest information, click here.

On September 11, 2024 the Portugal government announced that the country will adopt the EU law requiring a minimum corporate tax rate of 15%. This change marks an important financial policy for the country, given that the new rate is lower than the current standard corporate tax rate of 21%. The new rate will apply to large multinational companies, that have yearly revenues over €750 million.The new minimum tax rate is a component of the OECD’s global tax agreement known as Pillar Two, that aims to prevent profit shifting by multinationals. Portugal had been warned earlier by the EU for delays in implementing this tax.
The Albanian Minister of Finance and the Swiss Ambassador to Albania signed an agreement for continued technical support in the country's local finance system. This agreement marks the second phase of the project, "Technical Assistance for Strengthening Local Public Finance Management in Albania," which provides with EUR 4.5 million in funding for the 2024-2028 timeframe. The fund will be used to support the implementation of the project.To read more on the specifics of the new tax brackets, click here.
On September 12, 2024, the Australian House of Representatives began reviewing the Treasury Laws Amendment Bill 2024. Key proposals include increasing the withholding rate on nonresident capital gains from 12.5% to 15% and removing the threshold for capital gains tax on nonresident CGT assets. The Bill also lets employers make payroll declarations for up to 12 months and gives the Commissioner authority to adjust assessments for small and medium businesses, starting from the 2024 tax year.For more details on the proposed changes, click here.
On September 11, 2024 the Jamaican Tax Administration announced that the original tax payment deadline of September 15, 2024 has been moved to September 16, 2024. This decision was made as original date falls on a weekend. The new deadline is applied for many taxes in the Q3 2024 such as the corporate income tax, stamp duty, and withholding tax.In addition, the notification reminds taxpayers to make the payments in person, or as well online within the provided deadline, to avoid penalties due to late payments.To read more on the details of the announcement, click here.

On September 10, 2024, the Canada Revenue Agency published their guideline that provide detailed information on the new Reporting Rules for the Digital Platform Operators. Among many aspects, the guidance explains who qualifies as a resident or nonresident "reporting platform operator" or "reportable seller."

In addition, the new rules require the platform operators to report to the tax authority the identification and activity data on their reportable sellers. The first information return must be submitted by January 31, 2025, for the 2024 calendar year. Returns must be filed in XML format, with different processes for residents and nonresidents.

To read more on the details of the Rules, click here.

On September 10, 2024 the Polish Ministry of Finance opened a consultation on the recent draft bill which proposes new VAT regulations. The comments on the draft bill are due by September 24, 2024. Key changes proposed on the bill include:

  • 0% VAT rate on rescue vessels and lifeboats used at sea (excluding seagoing ships);
  • Extending the 8% VAT rate for certain medical devices and lowering the VAT on menstrual cups from 23% to 5%;
  • Extends the reverse charge mechanism for gas and electricity until the end of 2026;
  • Raises the VAT on certain hemp products from 8% to 23%.

To read more on the draft bill, click here.

On September 6, 2024 the Brazilian Official Gazette published Normative Instruction No. 2216, updating the list of tax benefits for legal entities. It includes 43 (forty-three) different tax incentives, waivers, and exemptions.

According to the new regulation, legal entities in Brazil must declare items 17 to 43 starting from the January 2024 assessment period. Additionally, the deadline to submit or correct declarations for tax incentives from January to August 2024 is October 20, 2024. The instruction replaces the annex of Normative Instruction No. 2198 and takes effect immediately.

To read more on the specifics of the Normative Act and provided instructions, click here.

On September 6, 2024 the Portuguese Government released a detailed set of FAQs addressing the updated 2024 personal income tax (IRS) withholding tables. These updates primarily apply to individuals who earn employment or pension income.

In the FAQ document, the government explained that any excess tax withheld on income between January to August 2024 will be adjusted by revising withholding rates applied in September and October. In addition, the information confirms that for those unable to implement the updated tables in September, the necessary adjustments must be made in October, ensuring that the excess withholdings are properly compensated during this period.

On September 5, 2024 the European Court of Justice (ECJ) issued its decision making on German VAT refund rules following Case No. C-83/23. The case involved a German taxpayer who took over a German limited partnership engaged in sale-and-leaseback transactions. The taxpayer purchased boats from a German supplier, who applied German VAT on boats bought from Italy. These were treated as intra-community supplies, and the taxpayer claimed a VAT deduction. However, the German tax authority rejected the deduction. After the supplier went bankrupt, the taxpayer sought a VAT recalculation, which was also denied. The ECJ upheld the tax authority’s decision, ruling that under EU VAT rules, a service recipient cannot request a VAT refund if the supplier, now insolvent, has already received the refund.To learn more on the case, you can access the ECJ Ruling here.
On September 5, 2024 the Azerbaijani Cabinet of Ministers published Decision No. 383, where it provides with the list of fixed assets that will be exempt from import VAT under leasing contracts. The decision explains which assets qualify for tax exemption, as the government aims to promote economic growth and attract foreign investments.To learn more on the list of assets, click here.
Sweden plans to cut income taxes in 2025 to help households hit by rising prices and borrowing costs. The measure, part of next year’s budget, will cost around 13.5 billion kronor ($1.31 billion), with another 4.4 billion kronor allocated to make some stock and mutual fund savings tax-exempt. The government aims to support households after declaring victory over inflation, which previously limited spending to avoid worsening price increases. The full budget, including 60 billion kronor for additional support and infrastructure, will be presented on September 19, 2024.

On September 4, 2024, during an event in Brussels the director general of the Italian treasury called for EU's attention to implement a digital services tax. The proposal was presented in the scope of providing a temporary solution while global negotiations on reallocating profits of multinational companies continue.

Italy addressed its concerns on the slow progress of global tax reform under the OECD’s Pillar One initiative, which aims to reallocate multinationals’ profits. In addition, Italian representative suggested that revenue from such a tax could contribute to the EU’s budget, as countries like Italy, Spain, and France already do.

On September 4, 2024 the Swiss Official Gazette announced updated withholding tax rates and thresholds for direct federal taxes. The changes affect income from employment, as well as health, accident, disability, and unemployment insurance. Additionally, it impacts gross capital benefits for individuals living abroad who receive lump-sum pension payments.These new rules will take effect starting January 1, 2025.To read more on the specifics of the updated rates, click here.
On September 3, 2024 the Bulgarian National Revenue Agency announced important tax deadlines dates which are due in September 2024. Below is a summary of the upcoming deadlines organized by their respective dates:13 September 2024:
  • Intrastat declarations for intra-EU exports and imports for August.
  • VAT Information Exchange System (VIES) declarations for registered persons who have made specific supplies.
  • File and pay VAT for August.
14 September 2024:
  • Pay September's monthly advance corporate tax.
19 September 2024:
  • Intrastat declarations for intra-EU exports and imports for August (for newly registered Intrastat operators).
24 September 2024:
  • Employers must pay advance tax and social security contributions for August.
To read more on the specifics of each deadline, click here.

As of September 2024, multinational companies in Belgium can proceed with making advance tax payments under the new global minimum corporate tax rules. These payments are expected to be completed by 20 December 2024 and in case of non-payment companies might face a surcharge.

This policy concerns the top-up taxes under the Qualified Domestic Minimum Top-up Tax and Income Inclusion Rule regimes, ensuring a minimum 15% corporate tax is collected when there are differences in tax rates across countries.

As a reminder, Belgium has also extended the registration deadline for the global minimum tax rules to 16 September 2024 for companies not making advance payments this year.

To read more on the specifics of the communication click here.

On September 2, 2024 the Swiss Federal Tax Administration updated cantonal withholding tax rates for income and payroll accounting (ERP) systems. These updates apply to employers, software providers, insurance companies, and pension funds.

On September 2,2024 the Slovenian Parliament accepted Bill No. 1683-IX to amend the VAT Act. New provisions propose raising the VAT registration threshold from €50,000 to €60,000 and introduce rules for VAT group formation.

Notably, the bill also implements two EU directives: Directive 2020/285 on administrative cooperation and Directive 2022/542 on VAT rates. It exempts VAT on goods and services for natural disaster victims under certain conditions and limits reduced VAT rates for phytopharmaceuticals and fertilizers until December 31, 2031.

Additionally, the new rules provision cross-border VAT exemptions entitled to Slovenian tax residents who don't use the small tax exemption.

On September 2, 2024 the Danish Customs and Tax Administration published a binding ruling (No. SKM2024.430.SR) that clarifies the VAT exemption for management services of collective investment funds (CIFs).

The ruling followed the case of an investment management company that claimed its services namely, Undertakings for Collective Investment in Transferable Securities and Alternative Investment Funds, covered by EU directives, were VAT-exempt. The Tax Council confirmed that these services are exempt from VAT as they are specifically designed for managing investment funds in compliance with the EU rules.

To read more on the arguments following the ruling, click here.

On September 2, 2024 the New Zealand Inland Revenue made the following online announcements:

  • On August 29, 2024, the second protocol to the 2006 Double Tax Agreement (DTA) with Austria, signed on September 12, 2023, will come into force.
  • On November 1, 2024, the DTA and protocol with Slovakia, signed on September 26, 2023, will take effect.

To read more on the specifics of the announcement, click here.

On September 2, 2024 the Belgian Federal Public Service-Finance announced the deadline for advance payments related to the OECD Pillar Two – Income inclusion rule (IIR) is December 20, 2024. On our previous article, that can be accessed here, we covered the specifics of advance tax payments applicable in Belgium, under the new global minimum corporate tax rules.

Multinational and large domestic groups affected by the new tax rules can make their payments through the MyMinfin Pillar 2 VA module or by bank transfer.

To read more on the public announcement, click here.

On August 29, 2024 the Tax Administration of Kosovo announced the entry into force of Law No. 08/L-142 which amends among others, the tax scales in the annual personal income. Under the new law, the tax rates for personal income have been updated as follows:
  • Income up to €3,000 will be taxed at 0% tax.
  • Income from €3,000 to €5,400 will be taxed at 8% tax.
  • Income over €5,40 will be taxed €192 plus a 10% tax.
To read more on the specifics of the new tax brackets, click here.

On August 28, 2024 the Czech Chamber of Deputies moved forward with Bill No. 781/0, aiming to amend the 2013 Act on international tax cooperation, by proposing several key updates.

New rules allow the Tax Administrator to require taxpayers to maintain special records to ensure they meet specific obligations. It also introduces standardized reporting requirements for crypto-asset service providers and operators, including guidelines on notifications and document recordkeeping.

Additionally, the bill outlines the registration procedures for crypto-asset operators and further details due diligence procedures for those using crypto assets.

On August 27, 2024 the Taiwanese Ministry of Finance announced online important tax deadlines dates and procedures which are due in September 2024. Below is a summary of the upcoming deadlines applicable for profit-seeking enterprises:

Income tax declarations must be submitted between 1 September to 30 September 2024. The taxes’ calculations must be based on the previous year’s settlement, under the guidance of the relevant procedures.

The Ministry provides with a variety of channels to pay the taxes, including electronic payments, via financial institutions, via ATMs, or at convenience stores for amounts that fall under NT$30,000 (around US$940).

Additionally, the announcement confirms that certain enterprises, including sole proprietorships, partnerships, and small-scale businesses, qualify for exemptions from provisional payment requirements.

On August 27, 2024 the Serbian Tax Administration announced online important tax deadlines dates which are due in September 2024. Below is a summary of the upcoming deadlines organized by their respective dates:

2 September 2024: Payment of mandatory social insurance contributions for unpaid July wages.

5 September 2024: Payment for entertainment contracts and employing individuals with disabilities.

10 September 2024: Payment of non-life insurance premiums.

16 September 2024: Payment of mandatory social contributions, advance corporate income tax, contributions for nonresident pensioners, and contributions for domestic citizens employed abroad. As well this date is applicable for VAT payers primarily involved in international trade, who need to use Form PID VAT 1 for their declarations.

30 September 2024: Payment of August mandatory social insurance contributions for unpaid wages.

To read more on the specifics of the September 2024 tax deadlines, click here.

On August 27, 2024 the Kosovar Tax Administration announced updates to personal income tax rates. Expected to take effect on 23 August 2024, the new rates are as follows:
  • 0% Tax will be levied on monthly income up to EUR 250, or annual income up to EUR 3,000.
  • 8% Tax will be levied on monthly income between EUR 250 and EUR 450 euros, or annual income between EUR 3,000 and EUR 5,400.
  • 10% Tax will be levied on monthly income above EUR 450 euros, or annual income over EUR 5,400.
To read more on the details regarding the new rules click here.
On August 27, 2024 the Italian Revenue Agency announced important tax deadlines dates which are due in September 2024. Below is a summary of the upcoming deadlines organized by their respective dates:16 September 2024:
  • Payment of IRES and IRPEF installments for the 2023 balance and the first advance for 2024.
  • Payment of the regional tax on productive activities (IRAP) for the 2023 balance and the first advance for 2024.
  • Payment of ethical tax.
  • Payment of entertainment taxes, Tobin taxes, substitute taxes, VAT for August, and the third installment of 2023 VAT balances.
20 September 2024:
  • Deadline for submitting specific communications to the Tax Agency.
30 September 2024:
  • Payment of car taxes, VAT on intra-community purchases, and additional tax on vehicle tax.
  • Filing of specific declarations, including those related to IRPEF.
  • Deadline for reporting data on Q2 2024 VAT settlements.
On August 23, 2024 the HM Revenue and Customs in the UK published the updated list of gold coins exempt from VAT for 2024. The notice, among others, specifically clarifies that the VAT exemption applies only for gold coins with no less than 90% purity. Additionally, it defines the criteria of coins qualifying for investment gold, and provides an updated list of VAT-exempt investment gold coins.To learn more on the specifics of the notice in the matter , click here.

On August 23, 2024 the Romanian National Agency for Fiscal Administration announced the tax filing and payment deadlines for September 2024.

The following important key dates need your attention:

  • 6 September 2024: Deadline for VAT-taxable persons making intra-community purchases in Romania to switch their fiscal period from quarterly to monthly.
  • 10 September 2024: Deadline to apply for or terminate the special regime for farmers.
  • 20 September 2024: Deadline to apply for or terminate the VAT system.
  • 25 September 2024: Deadline to submit declarations for social contributions, income tax, and specific VAT obligations.
  • 30 September 2024: Deadline to submit VAT One-Stop-Shop (OSS) declarations.
On August 22, 2024 the Swiss Official Gazette announced the amendment of the VAT Act by the means of Law No. FF 2024 438. The law introduces several significant changes to rules and procedures, expected to take effect as of January 1, 2025.Among the amendments, the law defines the role and responsibilities of digital platforms, particularly in how they connect buyers and sellers. It outlines conditions under which a platform operator is not considered a service provider and exempts various medical and educational services from the VAT liability. Furthermore, it clarifies how advance payments should be handled under the flat-rate method.These updates aim to bring more clarity and structure to the VAT framework in Switzerland.

On August 22, 2024 the Danish Customs and Tax Administration published the City Court decision regarding tax residence and liability. The case subject to the decision concerned a Danish taxpayer who left Denmark in 2007 but was later deemed liable by the tax agency for taxes starting from January 1, 2014.

The City Court decision confirmed the National Tax Court’s earlier ruling, affirming that the deadline for income tax notices under Section 26(1) of the Tax Administration Act does not prevent the tax authority from establishing tax liability as of January 1, provided the taxpayer spent more than 180 days in Denmark during the previous year.

On August 22, 2024 the Danish Customs and Tax Administration published National Tax Court Decision, which clarifies the conditions for partially deducting VAT on expenses. The decision followed the assessment of the case pertaining to a taxpayer engaged in various taxable activities, including real estate brokerage. The National Tax Court partially upheld the Tax Agency's decision to allow only a partial VAT deduction on the taxpayer's general costs.The Court confirmed the following practices regarding VAT deductions:
  1. Taxpayers engaged in both taxable and non-taxable activities are only eligible for partial VAT deductions on general costs.
  2. Deductions must be reassessed when future transactions, such as fees from subsequent years, are incorrectly included in prior-year calculations.
  3. Full VAT deductions are applicable when expenses, such as brokerage fees, are directly related to taxable transactions.
On August 22, 2024 the Czech Ministry of Finance published the updated list of jurisdictions participating in the Multilateral Competent Authority Agreement (MCAA). This agreement facilitates the automatic exchange of financial account information using the common reporting standard.To access the list of the countries, click here.

On August 21, 2024 the Argentine Official Gazette announced the annulment of the VAT and income tax withholding regimes related to electronic payments. The Resolution issued on this matter further clarified that the new rules will be applicable for payments starting September 1, 2024.

To learn more on the matter, click here.

Germany, is a signatory party of the Convention on Mutual Administrative Assistance in Tax Matter, which has been amended by the 2010 Protocol. On August 21, 2024 the German Official Gazette provided with un update on the convention, announcing Indonesia’s partial withdrawal of its reservation under Article 30 of the Convention.To learn more about the notice, click here.

On August 15, 2024 the Moldovan State Tax Service issued in its website an order addressing feedback on frequently asked questions (FAQs) about VAT, income tax, and real estate tax. It covered a variety of tax aspects, while the following are some of the key information highlighted in the order:

  1. The VAT payment deadline for taxpayers not registered as VAT payers but who received import services is the 25th of the month following the import.
  2. The Order clarifies tax obligations for companies when giving gifts to employees during professional award ceremonies.
  3. Provides detailed information on how special and standard tax regimes are applied to real estate tax calculations for IT park residents.
On August 15,2024 the Montenegrin Government proposed a draft bill to amend the VAT Law. The bill aims to revise the categories of goods, services, and imports eligible for reduced VAT rates. For example, it adjusts a 7% rate for basic food products and medications, and a 15% rate for items like books and accommodation services. It also updates the list of VAT-exempt imports and other applicable rates.Additionally, the bill proposes applying the reduced 15% rate to marina services until Montenegro joins the EU. If passed, the law would take effect on January 1, 2025.To learn more about the Draft Bill, click here.

On August 9, 2024 the North Macedonian Public Revenue Office clarified that August 26,2024 is the deadline to file VAT tax returns for July 2024. In addition, the announcement also highlighted that taxpayers are required to file their returns, even if they had no taxable turnover during the reporting period.

On August 8, the South Korean National Tax Service announced several tax-related measures in a press release. The new rules allow companies to request up to a nine-month extension for corporate tax prepayments due on 2 September 2024, if their fiscal year ends in December.

The tax amendments as well detail how taxpayers can apply online for payment deadline extensions, while informing those with overdue national taxes, that they may face property seizure and sales. However, a potential one-year deferral is provided for such sales. Additionally, the tax verification process for VAT, income tax, and corporate tax reporting will be postponed to the second half of 2024.

To read more about the tax amendments, as provided in the Korean Language, click here.

In July 2024, Hungary reached a large budget surplus amounting to HUF 213 billion, namely the largest surplus in two years. It is estimated that the surplus is a result of tax increases and spending cuts measures implemented by the government, while addressing the growing deficit.The budget surplus will be used to reduce the cash-flow deficit equaling to HUF 2.44 trillion, relying on the expectations that the fiscal adjustment package will boost the budget balance by HUF 1 trillion. Furthermore, the Hungarian government seeks to achieve a 4.5% of GDP deficit target for the year.
On August 7, 2024 the Taiwanese Official Gazette published a Presidential Decree amending the Income Tax Act. The decree introduces new rules and provides details on income types which are subject to withholding tax.Among the many amendments, the new rules on taxation provide that in case a surplus need to be distributed to a sole proprietor or partner in a nonresident partnership, the withholding agent must withhold the tax before the deadline for annual settlement or liquidation. Additionally, withholding agents are required to submit tax payments for the previous month by the 10th of each month.The decree also outlines specific situations that could lead to penalties.To access the Presidential Decree on the Income Tax Act, click here.
On August 7, 2024 the Portuguese Official Gazette announced new rules to the country's tax rates under the Individual Income Tax Code, as amended by Law No. 33/2024. The updated law, which entered into force on August 8, adjusts tax rates across different income brackets. Here's the breakdown:
  • 13% for income up to €7,703.
  • 5% for income between €7,703 – €11,623.
  • 22% for €11,623 to €16,472.
  • 25% for €16,472 to €21,321.
  • 32% for €21,321 to €27,146.
  • 5% for €27,146 to €39,791.
  • 5% for €39,791 to €43,000.
  • 45% for €43,000 to €80,000, and
  • 48% for income over €80,000.
You can access the Law No. 33/2024 text in Portuguese language here.
Ministry of Finance in Italy has proposed to double the flat levy on foreign income for wealthy new residents. The new rules increase the threshold from €100,000 to €200,000 per year and will affect foreign income; however, they will not be applicable for “extra profits” of financial and energy companies. Taxes on overseas earnings, gifts, and inheritance for 15 years will be exempted for those who move to Italy.Furthermore, the new rules increase the requirements for foreign tax credits, and provision rules for reported and unreported investment fund distributions. The new measures are expected to be implemented on January 1, 2025.
On August 6, 2024 the Italian Official Gazette announced a new decree offering tax credits for companies investing in innovative energy-saving technologies. These credits are available to both resident companies and nonresident permanent establishments that make qualifying investments between January 1, 2024, and December 31, 2025.The decree outlines several key measures, among which: the tax credit amount will vary depending on the level of energy reduction achieved and the investment made; any unused tax credits by the end of 2025 can be claimed in up to five equal installments; and taxpayers must obtain certifications from qualified providers to be eligible for the credit.

On August 6,2024 the Austrian Federal Ministry of Finance made public the Federal Finance Court’s Decision regarding a company's corporate tax obligations. The company in question had its articles of association drafted on March 17, 2021, and officially registered on April 9, 2021. However, the company already had a registered internet domain before these official steps were completed.

The Tax Office initially charged the company a minimum corporate tax of €375 which covered three quarters of the tax year. The company disagreed, arguing they should only owe €250 euros for two quarters.

The Federal Finance Court ruled against the company, confirming it was subject to unlimited corporate tax liability. Since the company had an external presence before formal registration, the court decided they were liable from the moment their articles of association were established and owed the minimum tax for three quarters of the year.

You can access the Federal Finance Court Decision in German language here.

In October 2024, Peru will begin to apply a withholding tax to foreign digital platforms that provide services to local customers. This shift is in accordance with the rules of the OECD, as stated in the official gazette decree of the Ministry of Finance. Financial intermediaries will collect this tax if the payments are not remitted directly to the service providers abroad. Within 30 days, the withholding tax rate, which is yet to be determined, will be within the range of 0.5% to 50%. The tax office will frequently examine the accuracy of platform payments.

On April 2, 2024 the European Union Official Gazette published a preliminary ruling by the European Court of Justice (ECJ) concerning Bulgaria's reduced VAT rate on accommodations. A Bulgarian company in the tourism and accommodation sector applied a 9% VAT rate on certain transactions During an inspection, the tax authorities discovered that the company was not eligible for the reduced rate due to the lack of a categorization certificate. In this connection, the VAT was recalculated at a standard rate of 20 percent.The European Court of Justice Guidance addressed two issues:
  • The directive 2006/112/EC of the Council on the common VAT system states that the laws of the country do not require a categorization certificate for applying reduced VAT rates to accommodations unless the law precisely outlines the aspects of the category.
  • In cases where national laws limit the reduced VAT rate just to certain categories irrespective of other circumstances this is a mistake of principle of fiscal neutrality.
To access the ECJ ruling on the matter click here.

On August 1,2024 the Finnish Tax Administration released guidance No. VH/3968/00.01.00/2024 updating international double taxation in corporate tax matters. The guidance analyzes issues concerning double taxation, and the regulations that apply. Furthermore, it addresses multiple methods for eliminating double taxation, such as the refund method, release method, and other strategies.

Regarding tax procedures, the guidance covers procedures on how to handle certificates of residence and submit refund claims, while explaining the mutual agreement procedure for resolving double taxation issues.

To read more on the guidance click here.

On July 31, the Rumanian Agency for Fiscal Administration announced tax filing deadlines corresponding to various dates in August 2024, as follows:

By August 7, VAT-registered entities involved in intra-community purchases must make sure to declare any changes to their fiscal period. Farmers who wish to either enter or exit the special tax regime need to proceed with the declarations by August 12.

Another important date is August 20, by which businesses need to decide whether to apply for or terminate their participation in the VAT system. Furthermore, in August 26 declarations related to social contributions, income tax, and specific VAT obligations are expected to be submitted. Finally, by August 31 the VAT One-Stop-Shop (OSS) declarations must be submitted, wrapping up the month’s tax responsibilities.

To learn more about the taxation deadlines click here.

On July 31, 2024 the European Commission launched an inquiry to evaluate the enforcement of the Anti-Tax Avoidance Directive (ATAD1) and its amendment (ATAD2) since January 1, 2020. The purpose of this survey is to gather information on the effectiveness of these measures in addressing aggressive tax planning and review the policy choices made by EU member states. Additionally, it seeks to assess how well the measures align with EU Directive 2022/2523 on a new 15% global minimum tax, and determine if any changes are needed. Comments are due by September 11, 2024.

To learn more about the initiative click here.

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The Austrian Official Gazette issued Regulation No. 213, which established new requirements for issuing tax certificates and submitting reports related to capital gains tax withholding. This regulation provides that those who deduct capital gains tax should issue tax certificates upon request, and individuals subject to tax should file reports by March 31 of the following year.Additionally, it provides with the necessary content for these reports, increases the requirements for foreign tax credits, and stipulates rules for reported and unreported investment fund distributions. The new rules are expected to be implemented on January 1, 2025.
On July 29, 2024 Spanish Official Gazette announced that the Double Tax Agreement (DTA) with Paraguay is expected to enter in force on October 14, 2024. The DTA, signed between the countries on March 25, 2023, can be accessed here.
On July 29, 2024 the Italian Revenue Agency announced updated deadlines for tax filings and payments due in August 2024. Notably, August 20 is now the key date for several important tax obligations. This includes regional tax for the 2023 balance and first advance for 2024, sixth VAT installment for 2023, withholding taxes, and VAT payments for the first quarter and the previous month. Additionally, the deadline covers entertainment taxes, Tobin taxes, substitute taxes and IRPEF substitute tax.

On July 27, 2024 the Bolivian National Tax Service through Resolution No. 102400000016, extended the deadline for Corporate Income Tax filings to August 30, 2024. Subjects that can benefit from the extension include taxpayers with fiscal year closures as of March 31. The deadline applies for the submission of financial statements, annual external audit reports, minimum tax procedures reports, tax opinions, and Transfer Pricing Study. Important to note, the new deadline does not apply for the filing and payment of the corporate income tax Affidavit, which remains unchanged.

To access the Resolution click here.

Bolivia

On July 26, 2024 the Georgian Revenue Service reminded taxpayers of the upcoming July 31 deadline for paying Q2 2024 VAT taxe. This deadline applies to nonresident digital service providers, who are expected to proceed with the payments at the relevant account of the State Treasury of the Ministry of Finance. To access the announcement click here.
On July 9, 2024 Australia consolidated the text of the Social Security Act 1999 (SSA) by Act No.191 published on the Australian Official Gazette on July 26, 2024. To access the content of the SSA click here.
On July 25, 2024 the Greek Ministry of Finance announced the deadlines for income tax returns. Individuals are required to file their returns and make the first installment payment by August 2. Corporations have until August 9 to meet their filing and payment obligations. Furthermore, the announcement confirms that individual taxpayers who settle their taxes by July 31, 2024 could benefit from a one-time 3% discount on their payment.
Chile's Senate Finance Committee approved a bill to enhance tax compliance, allow for anonymous whistleblowers, and authorities to lift banking secrecy. The proposal, which aims to generate additional revenue equal to 1.5% of GDP for social spending, will now proceed to a Senate vote. Chilean Finance Minister expressed the urgency of passing the bill to include it in the next budget. Senators initially opposed to the bill agreed to support it in exchange for establishing a technical committee to oversee its implementation. The committee will review the use of anonymous whistleblowers, limited to cases of tax fraud or organized crime, and the lifting of banking secrecy.
On July 25, 2024 the Bulgarian National Revenue Agency reminded taxpayers of the upcoming July 31 deadline for filing and paying Q2 2024 taxes. This deadline applies to a wide range of taxpayers, including certain enterprises, self-insurers, and individuals who earned income from rent or other business activities in Q2. The taxpayers are required to pay advance tax by this date, while highlighting that taxes can be paid through the specified online portal.

On July 2024, the General Directorate of Taxes in Albania announced that taxpayers must declare, through e-Filing, the status of ownership or non-ownership of the premises where they conduct their economic activities by October 20, 2024. In addition, the taxpayers need to submit the relevant documentation to certify this status such as property documents and lease contracts.

Failure to declare the address of the premises where the business activity is conducted will be considered an administrative offense by law.

To learn more on the details of the new rule click here.

On July 24, 2024 the French General Directorate of Public Finance kicked off a consultation to update the VAT liability rules for imports. The proposed changes aim to address several key points. First, they clarify that VAT on certain imports can still be declared and paid to the Directorate of Customs and Indirect Taxes (DGDDI). Second, they would make specific resellers responsible for VAT on imports if there's a discrepancy between the declared tax base and the actual value of the goods. The draft also seeks to align VAT liability rules with the Union Customs Code and improve how delivery locations for goods are determined. The public can input their feedback until October 1st, 2024.

On July 24, 2024 the French General Directorate of Public Finance updated the list of tax treaties signed and enforced by France as of June 30, 2024. The list was updated by including new treaties with Luxembourg, Colombia, Denmark, Greece and Moldova.To access the list of tax treaties, click here.
On July 24, the Bosnian-Herzegovinian Tax Administration announced an extension of the payment deadline to January 1, 2025. This extension applies to obligations based on the principal amount and the costs of the compulsory collection procedure that were due by December 31, 2022. The announcement further clarified that taxpayers who settle the entire principal amount and the collection costs by the new deadline will be eligible for an interest write-off.
The Polish Lower House of Parliament, took into the consideration to review Bill No. 322/2024, seeking to bring forth changes to the Personal Income Tax Act. Among the amendments, one change includes the establishment of a tax table for the calculation of income tax. In addition, it establishes that a tax deduction will equal to 12 times the minimum wage, but no less than a minimum of 7,200 Polish zlotys (equivalent to $1,833).  If approved, the law will take effect on January 1, 2025.
The Norwegian Tax Administration released Tax Appeals Board Decision No. SKNA12-2024-16, concerning a voluntary VAT registration case. It follows the case of a taxpayer who rented out the first floor of a building to a restaurant. The Tax Office denied VAT deductions on rent and tenant improvement expenses, citing that the sublet wasn't part of the registered business. The taxpayer appealed, arguing the sublet should qualify for VAT deductions.Tax Appeals Board disagreed and stated firstly that leasing real estate was generally exempt from VAT from mid-2018 to early 2021, and those required to pay VAT had to actively choose to apply it. Secondly the taxpayer didn’t see the arrangement with the restaurant as a rental. As a result, there was no clear decision to apply VAT, so the taxpayer wasn’t eligible for the deductions.
Turkey is planning to adopt new tax policies, among which the introduction of a 15% minimum tax on multinational companies' profits earned in the country. If a multinational company pays less than 15% in taxes, they will need to pay the difference to reach that rate.Another planned measure includes the increase of the minimum monthly pension to 12,500 liras, adding an expected 33.2 billion liras ($1 billion) burden on the budget. Additionally, the corporate tax rate for companies involved in Build-Operate-Transfer and Public Private Partnership projects will rise from 25% to 30%. Lastly, it is expected that the departure fee for Turks traveling abroad will also increase, going from 150 liras to 500 liras per trip.
On July 15, 2024 the Italian Revenue Agency recently issued Answer No. 152/2024, explaining the special tax regime for individuals returning to Italy for internships. It follows the case of an Italian taxpayer who lived and worked in Germany from May 2020 to August 2023 before enrolling at an Italian university and receiving a monthly EUR 2,500 internship allowance. He inquired about eligibility for a special tax regime.The Tax Agency clarified that the regime's benefits are intended for income from work activities in Italy by individuals who transfer their tax residence there. However, income from training activities is excluded, and since the internship was part of his academic training and not a work relationship, the special regime did not apply to him.

The South Korean government is intending to propose a delay in cryptocurrency investments taxing income during the next year's tax revision proposal.

The proposal follows a three-year delay for the taxation plan. If approved, the taxation start date would move from January 1, 2025, to January 1, 2028. The Finance Ministry, however, stated that no decision has been made regarding this additional delay.

On July 12, 2024 Switzerland and Hungary signed a Second Protocol to the 2013 Double Tax Agreement (DTA) between the countries. The second protocol adopts the OECD's base erosion and profit shifting (BEPS) project's minimum standards and recommendations. Furthermore, it also includes a clause to prevent abuse.

On July 28, 2024 Australian Taxation Office announced that the deadline for filing and paying quarterly business activity statements is July 28. According to the notification, taxpayers will automatically you'll automatically receive a business activity statements (BAS), if they are registered for GST. In addition, it clarifies that even if the business is temporarily paused and there is nothing to report, the taxpayers still need to submit a nil BAS by the due date, either online or by phone.

On July 11,2024 the Italian Revenue Agency issued Answer No. 147/2024, providing guidance on VAT refunds for nonresidents. The case followed the case of a German company that received invoices from Italian suppliers with VAT applied at the standard rate of 22%. Although the taxpayer had not submitted a declaration, they wanted to know the correct procedure for obtaining a refund for the VAT surplus from passive operations.

The Tax Agency clarified that a taxpayer cannot recover the specified VAT surplus when the deadlines for doing so have passed. Additionally, the Agency affirmed that the right to retroactively attribute the specified VAT number is only possible if done within a reasonable time from the date of the first purchase transaction.

On July 11,2024 the Danish Customs and Tax Administration published Tax Council Binding Answer No. SKM2024.375.SR online, explaining dividend exemption under the Corporation Tax Act and the Equalization Act. The decision followed the case of a Danish company that sought clarification on whether its EU parent company would face Danish taxation due to its dividend distribution to the subsidiary.The Tax Agency concluded that the distribution didn’t cause taxation in Denmark because it complied with the EU Parent/Subsidiary Directive and didn’t breach the Equalization Act’s general avoidance clause. In addition, it concluded that the dividend distribution for earn-out payments wasn’t taxable in Denmark and that nonresident tax liability included domestic dividends with specific exemptions.

Switzerland is seeking to make digital platforms responsible for collecting VAT from sellers. The Swiss Federal Tax Administration has started a consultation on an amendment to its VAT law and aim to enforce this by January 1, 2025. The new changes in the law foresee to use platforms as the main suppliers for VAT purposes, requiring them to provide information on transactions and maintain records for up to 10 years. In addition, according to the new rules, the sellers will still be secondarily liable for paying VAT to reduce fraud.

On July 2nd, 2024 the Slovenian Financial Administration announced that the deadline for filing 2023 individual income tax returns is July 31. According to the announcement, tax calculations were issued based on data provided by taxpayers as of February 5. In addition, it clarifies that those who earned income but did not receive these calculations must file their returns themselves. The announcement, which can be accessed here, includes links to the income tax return form and the electronic declaration portal.

Hungary announced new taxes that will be imposed on financial and energy sectors, along with foreign-owned companies. Aiming to tackle the budget deficit, these taxes will specifically be levied on banks, multinational companies, and energy firms. Banks will need to pay these special taxes in full by 2024. In addition, the government plans to increase the transaction tax on banks and impose a new tax on their FX trades.

On July 5, 2024 the Portuguese Tax and Customs Authority announced that transfer pricing documentation deadline has been extended to July 31st. To access the announcement, you can click here and learn more on the procedure.

On July 5, 2024 the Croatian Parliament decided to consider Bills PZ 35 and PZ 36, which aim to amend the VAT law. The proposed changes include raising the VAT threshold for small taxpayers from EUR 40,000 (US$43,317) to EUR 60,000 (US$64,975). In addition, the bills define the criteria for small taxpayers, such as not exceeding EUR 60,000 in goods or services in the previous or current year. Click here to access the Bills.

The Belgian Federal Public Service-Finance has extended the deadline for filing 2023 individual income tax returns online from July 15 to July 19. The announcement also provided that taxpayers who have already submitted their returns, can make corrections using the MyMinfin application until July 15.

On July 4,2024 the Finnish Tax Administration published the Central Tax Board Decision (No. KVL:2024/26), clarifying VAT implications related to certain property transfers. The case involved a mutual real estate joint-stock company that owned a building with both residential apartments and business premises. This company also owned and managed 41 parking spaces in the building's garage. The dispute arose as a shareholder, who managed and rented out the apartments and business premises, did not receive the parking rights from the company.

The Central Tax Board established two important guidelines: First, when parking rights are transferred to tenants along with residential or business premises, this transaction should be treated as a single economic entity. Second, granting parking rights, even for undesignated spaces, does not qualify as a VAT-liable activity or for VAT deductions, as it falls outside the VAT Directive's definition of immovable property rental.

On July 3, 2024, the Public Revenue Office in North Macedonia publicly announced that VAT Tax Returns need to be filed by latest July 25. The notification reminds taxpayers to file their returns on time and comply with the rules.

The Slovenian Ministry of Finance announced on June 27, 2024 its online guidance on international taxation of dividends, interest, and income from property rights. The guidance covers taxation rules under Slovenian laws and international agreements, exemptions from taxes under EU directives and agreements like the automatic exchange of data on financial accounts. Additionally, it includes the application of the Multilateral Convention to prevent base erosion and profit shifting.

On June 20, 2024 the European Court of Justice published a ruling on Portuguese stamp duty for short-term cash transactions. The case followed a Portuguese automotive subcontracting company taxpayer granted a loan to its parent company through a cash pooling agreement and faced additional taxes from the Portuguese Tax and Customs Authority. The company contested this, leading to questions about the fairness of Portuguese law, which exempts domestic but not cross-border loans from stamp duty. The European Court of Justice decided that under Article 63 of the Treaty on the Functioning of the European Union, it is not allowed to exempt domestic loans from stamp duty while charging it on cross-border loans.

On July 8, 2024 the Czech Ministry of Finance provided online the updated list of the Double Tax Agreements (DTAs). The list, which can be accessed here, is composed of DTAs that are currently into force.
On June 24 2024 the Swedish Tax Agency released Statement No. 8-2956586, explaining when goods temporarily imported into Sweden can be exempt from VAT. The statement was issued in response to a taxpayer's question about when goods transferred to Sweden for temporary use in providing services could be exempt from VAT. The Tax Agency explained that, when a business moves goods between EU countries for business purposes, it counts as a taxable transfer, like selling goods, and is treated as an intra-Union acquisition. However, bringing goods into Sweden from another country isn’t considered a taxable transfer if certain criteria are met: the goods must be used to provide services in Sweden, used temporarily, and transported from the service provider’s home country. If these conditions are not met or change, the initially exempt transport can be retrospectively deemed a taxable transfer.
The Italian Ministry of Economy and Finance recently announced the increase of the tax period’s labor cost deductions beyond December 31st, 2023. According to the new rules, the businesses will benefit from a deduction of 20% from the costs of hiring new permanent employees and an additional 10 % for those who need more protection. In order for the businesses to benefit from these deductions it is required for them to have been operating for at least one year before the relevant tax period.

On June 20, 2024 the Swedish Tax Agency issued Clarification No. 8-2936141 explaining the deduction and calculation of foreign taxes for individuals with numerous income sources taxed abroad. According to the Clarification, both direct and common costs are to be considered when assessing foreign taxes. It  provided with the confirmation that  foreign tax deductions are based on income before deducting common expenses. Furthermore, the foreign tax on income taxed by Sweden cannot exceed the tax already paid abroad and tax reductions must be distributed among the applicable taxes and fees they are meant to reduce.

The German Parliament (Bundestag) decided to review Bill No. 20/10820. This bill aims to ratify the Multilateral Convention (MLI) to implement measures to prevent tax evasion and profit shifting signed on June 7, 2017, with Croatia, France, the Czech Republic,  Greece, Malta, Japan, Hungary, Spain, and Slovakia. The bill involves two key measures: Incorporating the OECD's minimum standards and recommendations to prevent treaty abuse and Amending the Financial Administration Act to implement mutual agreement procedures (MAP) and arbitration processes for the relevant tax treaties.

On June 19, 2024 the Ministry of Finance of Finland announced an increase in the turnover limit for VAT liability for small businesses, effective January 1, 2025. The turnover limit for VAT taxation will be raised from EUR 15,000 euros to EUR 20,000. The revised threshold applies if the company's turnover for both the current and previous calendar years does not exceed 20,000 euros.

Estonia is opposing a VAT reform proposed by EU introducing a new tax regime on digital platforms like Bolt and Airbnb. Estonia has argued its opposition by claiming that taxing service providers for using digital platforms will unfairly burden small and medium-sized enterprises, affecting the competition. In alternative, Estonia proposes a voluntary opt-in approach for each country. However, on the other side, countries like Italy and Spain support the reform to collect VAT from platforms such as Airbnb and Booking.com.
On June 19, 2024, the Maltese Inland Revenue announced that the new deadline for individuals to file income tax returns manually is July 15, 2024. For electronic filings, the extended deadline is July 31, 2024.
Norway has introduced a minimum 15% tax rate in alignment with the 2021 global tax agreement and is now inviting feedback on the proposal. Norway is now administering the undertaxed profits rules (UTPR), allowing the country to increase taxes when a multinational’s parent or local subsidiary jurisdiction doesn’t meet the 15% minimum rate. Among the already implemented policies by Norway, are the qualified domestic minimum top-up tax, and the income inclusion rule.

On June 18, 2024 the German Ministry of Finance communicated that October 31, 2024 is the new deadline for taxpayers involved with foreign companies to submit declarations for the 2022 assessment year under the Foreign Tax Act. The extension aims to allow time for changes to declarations following the EU Anti-Tax Avoidance Directive.

On July 18, 2024 the Maltese VAT Authority provided new deadlines concerning VAT filings. Accoridng to the announcement, the filling and payment of VAT is due by July 15, while the tax concerning environmental contribution on accommodation is to be submitted and payed latest August 15.
On June 17, 2024 the South Korean Ministry of Strategy and Finance clarified the extension of the tax rate reductions for individual consumption taxes. According to the announcement, the temporary reduction for specified gasoline products will remain at 20 percent, down from 25 percent, and for other specified fuel products at 30 percent, down from 37 percent. The new deadline for both taxes is August 31, 2024. In addition, the Ministry confirmed a 15 percent reduction on the individual consumption tax for power generation fuels, due by December 31, 2024.
On June 14, 2024 the Czech Chamber of Deputies accepted Bill No. 726/0 for consideration, proposing amendments to the VAT Act. The bill aims to exempt small businesses in the EU with annual turnover under 2 million korunas (US$86,631) from being VAT payers in the Czech Republic. The businesses exceeding this threshold during the year, would qualify as VAT payers from January 1 of the next year. Additionally the bill explains the application criteria for reduced VAT rates on construction works and conditions for VAT refunds for unjust enrichment.

On June 14, the Swiss Federal Council approved a draft decree to ratify the sixth protocol to the 1971 DTA with Germany. The protocol includes measure to enforce the OECD BEPS standards, namely the anti-abuse provisions and mutual agreement procedures (MAP). Additionally, it addresses the adoption of the OECD's method for allocating corporate profits to permanent establishments.

The Greek Independent Public Revenue Authority clarified that the new extended deadline for legal entities to file their 2023 income tax returs, is July 26, 2024. The new deadline now coincides with the individual tax return filing deadline.
On June 13, 2024 Romania Government announced that it has proceeded with the approval of the administrative arrangement aiming to facilitate the implementation of the Social Security Agreement with the United States. Both documents have been signed on March 23, 2023.
Brazil's Lower House has voted on the Green Mobility and Innovation Program Bill, known as Mover, which allows taxing imported products up to $50. The Bill now needs final approval from the President.The Mover program is expected to be helpful for the automotive sector because many investments in Brazil in that sector are waiting for the government's bill provisions. Overall, the program is expected to enable industrial policies that support predictability and legal certainty.

Kosovo ratified the Social Security Agreement (SSA) with the Netherlands by the means of Law No. 08/L-263. The SSA was singed on September 17, 2020 and is expected to have entered into force by late June 2024.

On June 11, 2024  the Tax Administration of Republika Srpska, federal entity of  Bosnia and Herzegovina, published a new law introducing a withholding tax exemption.Exemptions apply to insurance premiums and interest paid to nonresidents without a permanent place of business in Republika Srpska. The law covers loans used by residents to finance projects considered of special importance by the National Assembly. The law came into effect on June 14, 2024.

On June 10, 2024 the Italian Ministry of Economy and Finance announced a flat-rate deduction for haulers in 2024. According to the new rules, entrepreneurs who personally handle transport outside their company's municipality can claim a 48-euro (US$51) deduction for undocumented expenses from the 2023 tax period. Additionally, for transport within the municipality, entrepreneurs can receive a tax relief amounting to 35 percent of the deduction for transport outside the municipality.

On June 10, 2024 the Polish Official Gazette announced an extension for the implementation of the mandatory national VAT e-invoicing system, commonly referred as KSeF. The new law postpones the mandatory use of KSeF for all active and VAT-exempt taxpayers from July 1, 2024, to February 1, 2026. Additionally, it introduces an interim period from February 1, 2026, to July 31, 2026, during which invoices can still be issued in the current manner without any penalties.

The law is expected to come into effect on July 1, 2024.

On June 10, 2024 the South Korean National Assembly assessed Bill No. 2200235 which seeks to partially revise the Restriction of Special Taxation Act. Changes proposed include extending credit card income deductions by three years, and increasing the deduction rate from 40% to 50% for spendings in traditional markets.

Switzerland is working on establishing rules for sharing tax information on remote salaries with France and Italy. A new bill proposed on early June 2024 aims to set guidelines for exchanging data between cantonal tax authorities and the Federal Tax Administration.

Furthermore, Switzerland signed an agreement with Italy to make remote work tax rules permanent, allowing up to 25% remote work without affecting tax liabilities. Also, Switzerland reached a similar agreement with France in June 2023, which is now under parliamentary review.

Starting July 1, 2024, Israeli citizens will no longer need a permit to work in the Czech Republic as per a notice from the Czech government. The new rules make it easier for Israeli citizens planning to relocate to the Czech Republic for work, as future employers will no longer be required to officially advertise the job position for Czech citizens first before hiring Israelis.

Israeli citizens can visit and stay in the Czech Republic for up to 90 days without a visa. But for longer stays and employment, they must apply for a "non-dual employee card," serving as a residency permit.

The new regulation also simplifies procedures for Israelis already working in the Czech Republic who wish to look into more work possibilities in the country. In the past, employees had to inform the Ministry at least 30 days ahead and wait for approval. Now, they can change employers more quickly by notifying the Ministry within just 3 days of the change.

German Government announced on June 5, 2024 the approval of Annual Tax Act 2024, which provisions several key measures. Among the new rules, Act mandates that credits provided by employers, in addition to wages, will be taxed at a flat rate of 25 %. Furthermore, the Act implements a reduction in the tax rate on the delivery and intra-community acquisition of artworks from 19 % to 7 %.

Additionally, the Act qualify landlords offering permanently subsidized housing to receive tax relief, and establish that bonus payments made by statutory health insurance companies for health-conscious behaviors, up to 150 euros, are considered now permanently tax-free.

Lastly, it extends the deferred taxation of monetary benefits from capital investments to share transfers in group companies.

On June 5, 2024 the Bulgarian National Revenue Agency introduced a special VAT regime for small businesses. The new rules allow for EU member states to set an annual turnover threshold of up to 85,000 euros for VAT exemption, and furthermore grant VAT relief to qualified taxpayers who are not based in the state where VAT is due.

Aiming to safeguard cross-border applications, an EU-wide turnover threshold of 100,000 euros has been set. Taxpayers with EU turnover below this threshold and below the national limit can benefit from exemptions. The regime is expected to become effective of January 1, 2025.

On June 5, 2024 Romania and Albania signed an administrative arrangement supporting the implementation of the Social Security Agreement (SSA). The Agreement was signed between the countries on the same day.

Currently, Albania is actively engaged in facilitating SSAs with EU countries.

Turkish Turkey Treasury and Finance Minister Simsek confirmed  that Türkiye is not planning to tax profits from stocks and cryptocurrency. Instead, the country is  rather considering implementing a "very limited" transaction tax on these assets, although the specific rate is yet to be determined. Concerns about the potential impact of this policy were raised by Ata Portfoy CEO, who suggested that even a small tax on stock trading could disrupt market efficiency.

Simsek, while leading efforts to address the country's inflation, emphasized the government's commitment to fair and efficient taxation. The Turkish government has already announced measures such as reducing public spending and proposing a minimum corporate tax rate as part of its fiscal consolidation efforts.

German Finance Minister has proposed €23 billion ($25 billion) in income-tax relief for households through 2026. The proposal includes increasing the tax-free allowance for low-income earners and adjusting earnings brackets to mitigate inflation. This proposal was presented during budget negotiations with coalition partners, while facing  a €20 billion shortfall for 2025.In alignment with institutional priorities, the German Ministry of Finance is advocating austerity measures, with the exception of defense spending. Meanwhile, the government is seeking to lift the constitutional debt limit to facilitate military support for Ukraine.
On June 4, 2024  the Cypriot Tax Department clarified that July 31 is the deadline for submitting withholding tax and contributions declarations (TF 7) for 2023. In addition,  the announcement also addressed that failure to meet this deadline may result in penalties.

On June 4,2024 the Slovak Financial Administration brough into the attention of individual and corporate taxpayers with foreign income that the extended deadline for 2023 tax returns and payments is July 1,2024. The notice confirmed that tax overpayment refunds will be processed by August 10,2024 and provided additional details on remittance, extensions, and payment plan application procedures.

The OECD's International Compliance Assurance Program (ICAP) now allows multinational companies to participate even if their parent corporation is based in a non-participating jurisdiction. This is achieved through a "surrogate lead tax administration" from a ICAP participating country, allowing companies to complete their risk assessment .

The ICAP program enables companies to discuss their transfer pricing positions with tax administrations, which helps to clarify their tax obligations. To request a surrogate, companies must have significant operations in the participating country and ensure that the tax administration is sufficiently acquainted with the company in order to request a surrogate. ICAP was established in 2018 and has since expanded to 23 participating countries.

Brazilian newspaper O Estado de S. Paulo published insights on the new proposal that aims to control "trusts," a financial tool used to manage assets outside of Brazil, in the wake of the country's tax overhaul. The Draft Proposal states that the Bill will regulate taxation in certain circumstances that have not been regulated up to this point, such as death, donation, or asset relinquishment.

On May 31, 2024 the Singaporean Inland Revenue Authority released an updated e-tax guide concerning the tax framework governing Variable Capital Companies (VCCs). The guide covers various aspects, including but not limited to, an overview of its purpose, relevant definitions, details on income tax treatment, GST treatment, and stamp duty treatment. Additionally, it outlines procedures for seeking clarification on the guide's content.

On February 6, 2024 Albania and Italy signed the Social Security Agreement. This Agreement was ratified by Albania under Law No. 47/2024 and published by the Albanian President through Decree No. 209 on May 31, 2024.

On May 30, 2024 the South Korean National Tax Service issued guidance concerning tax credits for earned income increases. This guidance addresses various aspects, such as an overview of the earned income increase tax system, eligibility criteria, and the calculation formula. Additionally, it clarifies the tax credits implicaitons for workers transitioning to full-time employment and outlines additional deductions for those transitioning to regular positions. The guidance further includes FAQs, calculation examples, and the standard forms to provide clarity and usability by citizens.

On May 30, the Maltese Inland Revenue explained the implications of the VAT Act, which provisions the treatment of interest under the VAT Act in alignment with that of the Income Tax Acts. As a result, the interest earned on income tax refunds will not be taxable, while the interest expenses are not to be deductible when calculating taxable income.

Additionally, taxpayers are directed to distribute VAT interest income and expenses that are not chargeable or deductible whenever included in tax returns for 2024-2025. The VAT Act aims to optimize tax procedures and ensure consistency in handling interest matters.

On May 30, 2024 the Finnish Parliament accepted to review the new Bill concerning the increase of general  Value-Added Tax (VAT)  and the Tax on Specific Insurance Premiums. The Bill proposes  raising the rate on taxes that become liable after September 1, 2024, from 24% to 25.5%. Additonally, after the Bill takes effect, the new rate will also apply to products obtained within the community.

On May 30, the Latvian State Revenue Service provided information on filing 2023 Individual Annual Income Tax Declarations. Among the provisions, some of the key rules include the announcement of submission deadlines of June 3 or July 1, based on last year's total income; the requirement to use the State Revenue Service's electronic declaration system (EDS) and mandatory declarations for those receiving low-income benefits.

Furthermore, the declarations will subject as well the residents with unreported income, such as self-employed earnings or foreign income. As per the announcement, the tax overpayment refunds will be issued within three months of filing.

On May 29, the French General Directorate of Public Finance communicated the extention of the VAT reverse charge mechanism. The updated rule now applies on the transfers of certificates related to guarantees of origin; and production of certificates in the electricity and gas sectors, according to new provisions in the Energy Code.

On May 29, the Danish Customs and Tax Administration published City Court Decision No. SKM2024.295.BR, addressing dual domicile, tax residence, and tax obligations under DTA (Double Tax Agreement) rules. Following the case of a dispute between a Danish resident and the Tax Agency on the tax liability under the DTA, the Court established that dual domicile can occur under DTA provisions.

However, to end Danish residence, a taxpayer must provide proof of terminating cohabitation with a spouse to end Danish residence. Additionally, the Court ruled that the Danish Tax Authority can exercise its taxing rights if the taxpayer does not submit evidence that their center of life interests has shifted to a foreign country.

On May 29, the Czech Ministry of Finance published an updated list of Double Taxation Agreements (DTAs) that are currently in effect. This comprehensive list is up-to-date ensures that all relevant information is accurate and reflects the latest changes and agreements. You can click here to access the list.

The Czech Ministry of Finance disclosed on May 21 that the Double Taxation Agreement (DTA) with the United Arab Emirates, signed on May 24, 2023, came into effect on May 13, 2024. As per the terms, the agreement will be enforced from January 1, 2025, and it will impact withholding taxes and all other taxes applicable to taxable periods starting on or after January 1, 2025.

The Cypriot Tax Department has set July 31, 2024 as the deadline for filing the 2023 income tax return. This applies for employees, pensioners, and self-employed individuals with gross total income exceeding 19,500 euros (US$21,135) for the year 2023.

In an interview with TRT Haber, the Turkish Treasury and Finance Minister Mehmet Simsek stated that the Turkish government is working on a plan to introduce a minimum corporate tax. Additionally, he mentioned a study on income from land and real estate, without giving further details.

The UK Tax Authority is seeking opinions on draft legislation to amend the application of its new penalty regime for late tax payments. The draft legislation, published recently, will grant His Majesty's Revenue and Customs the power to apply late payment penalties before the due tax has been fully paid.

Currently, penalties can be applied only after the overdue tax is fully paid and within a two-year assessment period. This measure aims to stop taxpayers from avoiding penalties by delaying tax payments until the end of the assessment period. The new penalty regime is points-based, with a fixed £200 fine for every two penalty points accumulated each time a taxpayer files a return late.

The French General Directorate of Public Finance issued an administrative doctrine concerning the taxation of capital gains and losses from business transfers involving non-real estate assets. It explains that capital gains are exempt from taxation for transfers of non-real estate assets, including sole proprietorships, complete branches of activity, or all rights or shares in partnerships considered as professional assets. Furthermore, a full exception applies if the market value of the assets is less than 500,000 euros, and a partial exception applies if the market value of the assets transferred is between 500,000 euros and 1 million euros.

Albania and Croatia on 2 October 2023 singed the bilateral Social Security Agreement. This Agreement is the first of its kind between the two countries, that is to be implementd after it enters into force. The Albanian Official Gazette issued Notice No. 7233, reporting that the social security agreement with Croatia came into force on May 1, 2024. Additionally, the Croatian Official Gazette published Decision No. 28, ratifying the administrative agreement to implement the social security agreement with Albania, effective from May 15.

The Czech Official Gazette released Notice No. 115, suspending Articles 10, 11, and 13 of the 1996 Double Taxation Agreement and the 2010 Protocol with Belarus from June 1, 2024, to December 31, 2026. The notice takes effect on May 29.

The European Commission recently has registered a European Union citizens' initiative that urges for more consideration of greenhouse-gas emissions and non-renewable natural resource consumption in policies designed to fight  global warming.

The initiative suggests using some emissions levy revenues to support low-income households, reducing the economic impact and increasing public support for carbon pricing.Despite its potential to significantly cut emissions, some EU governments and parts of the European Parliament view carbon pricing as an economic risk.

If  the initiative accumulates 1 (one) million signatures from citizens in at least seven EU countries within a year from the date of registration, the European Commission is expected to take an action on the matter.

European Union finance ministers recently will try to search for an acceptance  for new value-added and withholding tax rules, but must address objections from two countries in the bloc to succeed. Ministers, meeting in Brussels, will be requested to sign off on a package of three laws introducing digital VAT reporting and e-invoicing, new rules for online platforms, and a single VAT registration for companies operating in the EU.

On this matter, Estonia's position on the new rules was unclear due to pushback from the country, but as confirmed by their spokesperson, Estonia does not seek to block the plan. Rather, Estonia is conveying their concerns that the proposed plan for online platforms could affect VAT neutrality by limiting options for some service suppliers to deduct input VAT.

As EU seeks to replace current tax refund systems for cross-border dividend and interest payments with simpler procedures, Czechia, too, expressed disagreement with some of the proposal's basic principles, however further details were not provided.

Since the EU requires unanimous agreement on new tax rules, opposition from one country could delay agreement.

Two German finance agencies expressed their support for maintaining and possibly increasing funding for the EU program Fiscalis, which supports international efforts to combat tax fraud.

Fiscalis supports joint audits and training, and has facilitated joint audits and training programs, which the Bavarian Finance Administration and the German Ministry of Finance’s Baden-Wurttemberg office noted would not have been possible without its financial assistance. Additionally, the program, with a current budget of 269 million euros for the current 2021-27 period, also facilitates technology and best practice exchanges among EU tax authorities.

Recently, the Danish Customs and Tax Administration issued online City Court Decision No. SKM2024.267.BR, addressing the taxation of bank deposits. The case involved a Danish resident who faced additional income tax imposed by the Tax Agency on deposits from his mother’s company, which he claimed were gifts. The legal dispute raised on wheather certain bank deposits are to be considered as employment income or gifts. The City Court ultimately qualified the deposits as additional salary, and not gifts.

Recently, the Italian Revenue Agency released Circular No. 10/E, detailing measures concerning short-term property leasing. The directive specifies a 26%  flat tax rate on certain short-term lease contracts, a 21% withholding tax rate for real estate intermediaries and managers of specific electronic portals, and the obligations for non-resident intermediaries.

From September 2024, the United Kingdom will apply a 20% value-added tax (VAT) to the sale of voluntary carbon credits. Initially, these credits were exempt from VAT as they couldn't be resold, lacking a secondary market.

Certain transactions involving carbon credits will remain exempt from VAT, including the initial issuance by a public authority, holding credits as investments, donations to carbon credit projects, and sales from self-assessed projects without independent verification.

Additionally, from September, carbon credits will be eligible for VAT relief under the Terminal Markets Order, which eliminates the sales tax rate for wholesale commodity transactions on specified terminal markets, according to HM Revenue and Customs.

The OECD has published a report on the rules under Pillar One – Amount B of its global tax framework. This part of the agreement offers a simpler way to figure out a set return for basic marketing and distribution activities, called the Simplified and Streamlined Approach.

This approach aims to reduce transfer pricing disputes, compliance costs, and increase tax certainty for administrations and taxpayers. However, its optional implementation and limited scope complicate these goals.

Key considerations include determining transactions that meet the scoping criteria, applying the approach to eligible transactions, addressing transfer pricing documentation and tax certainty concerns.

Recently, the European Court of Justice (ECJ) issued a preliminary ruling for Case No. C-241/23, addressing the Poland VAT regulations concerning share exchanges. In this particular case, a VAT-registered company  aimed to raise its capital by accepting in-kind contributions from various entities, providing its shares in return for properties. These contributions were recorded in the VAT returns at net value, but the Tax Authority, supported by the Appellate Authority, confirmed that capital should be calculated using the shares' nominal value instead of their issue value.

Pursuant to Poland's Supreme Administrative Court request, the ECJ concluded that when a company contributes property to another company's capital in exchange for shares, the taxable amount should be based on the shares' issue value.

Recently the European Commission announced a consultation to evaluate administrative collaboration for direct taxation. The feedback is to assess how well the automatic exchange of information  is working for reportable cross-border arrangements (DAC6).

The evaluation aims to determine if the scope and purpose of DAC are still relevant and address issues faced by EU member states, particularly in ensuring accurate tax assessments in cross-border situations and combating tax avoidance and evasion. It will also examine how effectively DAC achieves its desired outcomes and impact, and evaluate the efficiency of information exchange and other specified tools from a cost-benefit perspective.

The Austrian Federal Ministry of Finance recently launched a consultation on a draft tax reporting ordinance. The ordinance seeks to establish reporting requirements and deadlines, clarifying procedures on how foreign withholding taxes can be used to reduce capital gains tax, and how they are assessed, and refine investment fund reporting. The ordinance is set to take effect on January 1, 2025, and it will be implemented for the first time in tax reports for the 2025 calendar year.

The Danish Customs and Tax Administration recently published the Supreme Court Judgment, explainin  transfer pricing adjustments in controlled transactions. Following the case involving a taxpayer parent company which established two nonresident oil production subsidiaries, which later acquired exploration licenses in the states where they were situated.

The tax authority found that the fees for these services from related parties didn’t match the fair market value, so it raised the disputed taxable income.  Upon appeal, the Supreme Court upheld this decision, ruling that the preliminary exploration phases, performance guarantees, and know-how had intrinsic economic value that would warrant continuous payments in an independent setting. The court also affirmed that the transactions among the companies were controlled transactions and that the costs charged didn’tmeet the arm's length standard because there were no ongoing payment obligations.

The Swedish Tax Agency recently upgraded its guidance on VAT treatment for mortgage sales. The modification clarifies a recent European Court of Justice (ECJ) ruling which explaines that arranging auctions for pledged goods wasn't considered a secondary or supporting activity to the main task of providing credit that is secured by the pledge. Consequently, these services don't qualify for the VAT exemption applicable to credit-granting services.

The Brazilian Official Legal structures recently released  Law No. 14,848, which updates the progressive table for monthly withholding of individual income tax. These adjustments came into effect from February 2024..The new rates are: 1) 0% for income up to BRL 2,259.20 (USD 441.92); 2) 7.5% for income from BRL 2,259.21 (USD 441.93) to BRL 2,826.65 (USD 553.01), with a deductible of BRL 169.44 (USD 33.14); 3) 15% for income from BRL 2,826.66 (USD 553.16) to BRL 3,751.05 (USD 734.05), with a deductible of BRL 381.44 (USD 74.64); 4) 22.5% for income from BRL 3,751.06 (USD 734.05) to BRL 4,664.68 (USD 912.88), with a deductible of BRL 662.77 (USD 129.70); and 5) 27.5% for income above BRL 4,664.68, with a deductible of BRL 896.00 (USD 175.00). The legislation canceles Provisional Measure No. 1,206, which had previously established the monthly rates effective from February 2024.

Recently, the Italian Revenue Agency published Provision No. 213637/2024, which clarifies the substitute tax option for controlled foreign companies (CFCs). The guidance addresses key topics such as relevant definitions,  the areas where the substitute tax option can be applied, and the procedures for opting in or revoking it. This provision it also outlines the conditions for terminating the option's effectiveness and provides a framework for calculating net accounting profits, subject to a 15% substitute tax rate. Moreover, it it outlines how subsidiary profits are taxed and the impact of using the substitute tax option on tax value monitoring.

The Danish Parliament has introduced Bill No. L 183 which promits  change different tax laws telated to  energy and fuel.. Key changes include phasing in a CO2 tax increase to 750 kroner per ton for non-EU quota companies and setting a 375 kroner per ton rate for quota-covered space heating from 2025 to 2030. A 125-kroner CO2 tax will also be applied to mineralogical processes. Furthemore, new CO2 taxes on fishing, domestic ferries, and aviation are proposed, along with the removal of floor deductions for certain companies. Additionally, the bill aims to reduce the energy tax for space heating, amend waste CO2 tax calculations to align with EU Directive 2003/96/EC, and standardize extraordinary tax liability resumption rules.

Recently, the Greek Independent Authority for Public Revenue announced  an extension for submitting 2023 individual income tax returns deadline along with several new filing process features for taxpayers. The new deadline for filing initial returns is set for July 1, with an extended date of July 26 for submitting amended returns without penalties. This year, certain taxpayers will receive automatic pre-filled tax declarations, which can be finalized by July 2 if the automatically filled data is verified to be correct. Additionally, taxpayers in Greece or abroad must now register an International Bank Account Number (IBAN) to receive tax refunds. Any tax refunds will be adjusted against existing tax liabilities up to July 31, and a 3 % (percent) deduction will be applied if the income tax is paid  through this method.

Recently, the United Kingdom's Foreign and Commonwealth Office has presented the bill to the Parliament, aiming to ratify a protocol pertaiing to the 2015 Double Taxation Agreement (DTA) with Sweden. The protocola was signed on February 23, 2021.

In late April, the Turkish Revenue Administration released a guidance on real estate taxation, covering various aspects. It clarifies which transactions are subject to title deed fees. These fees, set at 2 percent, are separately collected from both the buyer and seller, calculated based on either the actual transaction price or the property tax value, whichever is higher.

As well, the guidance addresses penalties and appeals for discrepancies in declared purchase prices. Finally, it classifies as capital gains the income from selling real estate held for less than five years, with an exemption increase to 87,000 Turkish lira, previously 55,000 lira.

The Polish Ministry of Finance recently launched a public consultation on a proposed law aimed at aligning with an EU Directive to implement a minimum 15% tax rate globally, as per OECD guidelines. This draft legislation targets multinational and large domestic companies with revenues over €750 million in at least two of the past four years. The bill introduces several new measures, including a domestic top-up tax, rules for including income and addressing undertaxed profits. Additionally, it also outlines methods for calculating effective tax rates and additional tax amounts, with particular provisions for pass-through entities and permanent establishments.

Recently, the Belgian Federal Public Service Finance announced the  filing deadlines for 2024 individual income tax returns. Paper returns, which will be distributed in May, must be filed by June 30. Those choosing  for electronic submission, including returns filed by agents on behalf of taxpayers, have a deadline until July 15. Additionally, individuals reporting specific types of income, such as foreign professional income, are given an extended deadline until October 16.

The Austrian Federal Ministry of Finance recently published a decision from the Federal Finance Court regarding an employer's obligation to withhold wage taxes and employer contributions for payments made to employees by third parties. The case involved a managing director of a company which voluntarily declared non-cash benefits for tax purposes, even though he had already paid income tax on them. However, during an audit, it was discovered that his employer failed to withhold the necessary taxes and contributions for these third-party payments. Despite the employer's claim that such payments were not subject to employer contributions, the tax office rejected their complaint. The Federal Finance Court supported this decision, confirming that third-party payments are part of taxable employment income and the employer should have managed the deductions since they were aware of these payments.

The Brazilian Federal Revenue Office recently released an upgraded version of its digital tax bookkeeping system, named ECF version 10.0.6. This update enhances the reporting process for corporate income taxes and social contributions on net income The latest version incorporates issues like error corrections in report generation and field rule adjustments, and also removes outdated registry keys. Additionally, the update improves the system's overall functionality. This version supports the submission of ECF files for the 2023 calendar year, 2024 special cases, and both new and amended filings from previous years.

The Institute of Statistics in Albania (INSTAT) has published key economic indicators for April 2024, including export/import levels and inflation rates.

According to data reported in the official website of INSTAT, exports of goods experienced a positive trend after nearly a year of contraction, reaching a value of ALL 35 billion in April 2024.

Additionally, the statistical data indicate a positive trend in the inflation rate, recorded at 2.1% in April, marking the lowest level for 2024. However, within various economic categories, the rent and energy sectors show an increasing pattern in inflation.

The Netherlands is considering revising its consumption tax on non-alcoholic drinks to include a sugar tax based on sugar content. Currently, the flat tax is set at 26.13 euros per 100 liters, generating significant revenue annually. The proposed sugar tax would potentially vary, with discussions about exemptions for certain drink categories such as mineral water, dairy, and all-natural fruit drinks.

The government has opened a consultation ,set to end by June 7th,  to gather opinions on distinguishing between natural and added sugars to effectively implement exemptions. State Secretary for Tax Affairs highlighted that maintaining the tax on all drinks would simplify administration, whereas exempting only mineral water could better align with public health objectives.

HM Revenue and Customs in the United Kingdom recently released an update VAT Notice No. 701/21A regarding VAT exemptions for gold coins in 2024. The notice provides that gold coins with less than 90 percent purity are not exempt from VAT, and provide clarification on the criteria for coins to qualify as investment gold coins. Additionally, HMRC provided an updated list of investment gold coins eligible for VAT exemption upon supply.

On April 9, the Dutch Ministry of Finance initiated a consultation on proposed regulations to modify the transfer tax exemption for real estate acquired through demergers, as outlined in the 2023 Budget Memorandum. The aim is to prevent tax evasion and simplify procedures. Proposed changes include introducing conditions such as a business requirement, continuity obligation, and retention clause. Stakeholders are invited to provide feedback by May 6th 2024.

The  Ministry of Finance in Montenegro has released a draft bill concerning the deduction of interest on overdue taxes for individuals, entrepreneurs, companies, and parts of companies. The bill provisions several measures, including granting taxpayers the right to deduct all interest on overdue taxes, fees, contributions, and other payments until December 31, 2024. However, The enjoyment of the relief depends on taxpayers submitting all overdue returns, resolving the principal tax debt, and requesting interest relief within 45 days following January 1, 2025. Additionally, the bill also covers tax debts previously rescheduled under past relief measures and the right to appeal on decisions made by tax authorities denying the relief.

In early April 2024, the Greek Ministry of Finance issued tax initiatives outlined in the 2025 budget, encompassing various measures. Among others, decreasing insurance contributions by 0.5%, permanently reinstating the Special Consumption Tax for farmers and temporarily suspending VAT on construction. Moreover, the measures further introduce a fresh institutional framework to stimulate business mergers and foster innovation through tax incentives. These measures signify efforts to improve fiscal policies and support key sectors within the Greek economy.

The French Ministry of Economy and Finance provided important dates for filing 2024 income tax returns. According to the updates, the resdients can start filing the tax returns electronically from April 11th, 2024, whilst nonresidents can file tax declarations online by latest May 23, 2024. Additionally, the update outlines specific deadlines for different zones. Furthermore, paper declarations, including those for French residents living abroad, must be submitted by May 21. Income tax notices will be issued during July and August 2024.

In April 2024, the Finnish Tax Administration revised its Guidance No. VH/253/00.01.00/2024, providing updated instructions for businesses concerning VAT deductions associated to real estate investments. The Guidance covers several procedural aspects such as timeframe for businesses to review their VAT deductions and procedures for correcting VAT deductions on tax. Additionally, it stipulates that the 10-year review period commences upon the completion of construction or improvements. The guidance became effective on April 9, 2024.

European Parliament lawmakers have endorsed plans for updated transfer pricing rules and a new tax head office system for smaller companies. The transfer pricing update aims to harmonize the legislations of all EU countries with OECD guidelines, ensuring transactions among related companies align with those among unrelated ones. On the other hand, the new tax head office system will allow small and medium-sized companies operating across EU borders to manage tax compliance through their head office country's tax administration. These measures aim to simplify compliance and facilitate cross-border tax management.

On March 2024, the Czech Government proposed a new draft bill to implement EU rules on administrative cooperation and tracking crypto-assets. In essence, the bill mandates that crypto businesses must register with the tax authority and disclose transactions made by Czech residents. The Central Bank will provide a list of authorized crypto businesses to the tax authority, while the law stipulates penalties up to 1.5 million Czech korunas for non-compliance with the rules of screening, investigation, recordkeeping and reporting inquiries.

In early April, Belgium's Federal Public Service-Finance provided an important updates regarding VAT return timelines and procedures. Among the measures outlined, the announcement specifies that April 20th is the deadline for Q1 filing for individuals choosing the general pro-rata deduction and seeking reallocation. July 20th is set as the deadline for Q2 declarations for the year 2024.  Additionally, taxable individuals are required to categorize incoming VAT invoices by sectors and submit final figures by October 21st for Q3 and by December 20th for November 2024. These updates aim to streamline VAT processes and ensure compliance among taxpayers.

The Austrian Federal Ministry of Finance clarified Court Decision No. GZ. RV/4100567/2022 providing assessment of the tax exemption on the sale of private property. This decision follows a case involving the sale of a residential building composed of two apartments by a taxpayer who, due to health reasons, relocated to another property. Following the trial, the Court ruled in favor of the tax office's argument, stating that the taxpayer did not meet the requirement of exclusively using two-thirds of the living space. Consequently, the taxpayer was subjected to a 30 percent tax rate on the proceeds from the property sale. Thus, this ruling reinforces the requirement for exclusive use of two-thirds of the living space in order to qualify for tax exemption on the sale of private property.

The Albanian Central Tax Administration in April 2024 provided updates regarding tax payments for businesses providing professional services. The updates declare that the 2024 taxes will be prepaid according to their 2023 self-declared profits, divided into installments with deadlines every three months throughout 2024. These prepayments will adhere to progressive tax rates, with individuals subject to a 15 percent tax on profits up to 4 million Albanian LEK (approximately US$146,519) and 23 percent on profits exceeding that amount. For non-individual taxpayers, a flat 15 percent tax rate will apply to prepayments , regardless of their total tax liability.

The Bosnian-Herzegovinian Tax Administration recently published the 2024 Rulebook composed of updated procedures for determining tax residency. It covers several key aspects, including criteria for determining residency for individuals based on factors like permanent home, vital interests, or habitual abode. Additionally, it outlines the processes and forms for issuing residency and non-residency certificates, along with provisions for denying non-residency certificates if there is no DTA between the country specified in the request and Bosnia. The rulebook also further elaborates relevant terms and guidelines such as "limited tax liability" and "unlimited tax liability".

In February, the Canadian Revenue Agency (CRA) announced updated annual interest rates for tax underpayments and overpayments for the first and second quarters of 2024. The announcement covers various taxes, including income tax, Goods and Services Tax and the Harmonized Sales Tax. Among the key highlights of the interest rates is the increase in the interest rate on overdue taxes, Canada Pension Plan contributions, and employment insurance premiums from 9% to 10% for both Q1 and Q2. Additional increase rates impact corporate taxpayer overpayments from 5% to 6, non-corporate taxpayer overpayments from 7% to 8%.

Early this April, the Finnish Tax Administration released Guidance No. VH/82/00.01.00/, updating information on the individual income taxation of business and professional income earned by foreigners in Finland. The guidance clarifies several aspects, such as determination of when construction contracting becomes a permanent establishment (PE) and the conditions for advance debt collection registration requiring the right to conduct business in the country. Among the key matters addressed, the guidance provides with an overview of social contributions and discussion on the impact of Double Taxation Agreements (DTAs) on taxation rights.

In April 2024, the Hungarian National Tax and Customs Administration issued clarification on the social contribution tax liability for certain nonresidents, effective from January 1st. The Administration stipulates that income earned from previous work by individuals insured in Hungary until December 31st, 2023, previously exempt from social contribution tax, is now taxable. This update aims to ensure compliance with tax regulations and address changes in tax liability for nonresidents in Hungary.

The Spanish State Tax Administration Agency has announced that July 1st, 2024 is the deadline for filing 2023 individual income tax declarations. While defining individual income tax, the Administration emphasizes that both residents in Spain and those abroad meeting specific criteria are required to declare. Additionally, it states that the declaration must include individual total income, capital gains, losses, and imputed income, irrespective of residency or where the taxable event occurred.

Early in April 2024, the United Kingdom HM Treasury updated the VAT registration threshold for small businesses, which has been raised from £85,000 to £90,000 . Furthermore, small business multiplier for business rates stays unchanged for the fourth consecutive year, and a reduction in national insurance contributions for working individuals will take effect at the start of the new business tax year. For UK independent films there will be a 53 percent tax credit on qualifying expenditures. These measures aim to support small businesses and encourage growth within the UK economy.

The Norwegian Finance Ministry announced a proposal to tax foreign sea-farming companies on incomes generated across the entire Norwegian continental shelf. Currently, there's no legislative basis for taxing such companies operating on the shelf. The continental shelf, a shallow seabed, falls under Norway's sovereignty for the exploitation of natural resources, spanning over 2 million square kilometers.

The proposal aims to extend taxation to foreign companies involved in sea farming and mineral extraction activities on the shelf, including taxing salaries of foreign employees. The proposal is open for public consultation until June 2024, with potential implementation in 2025 if approved.

In February 2024, the Lithuanian State Tax Inspectorate issued the guidance regarding the taxation of income acquired in 2023 from real estate sales. The guidance addresses essential aspects of real estate transactions, including the declaration and payment deadlines for income received in 2023 from real estate sales, the nontaxable holding period of 10 years on immovable property, taxation rules for sales made before the holding period ends, tax calculation methods, and documentation requirements.

Recently on March 2024, the Irish Revenue Commissioners issued Revenue eBrief No. 103/24, offering updated guidance regarding the payment and receipt of interest and royalties without the deduction of income tax. This guidance covers various topics such as withholding tax, interest payments to U.S. companies, and the tax treatment of companies operating under Hong Kong's territorial system. One of the introduced updates involves implementing defensive measures regarding outbound payments of interest and royalties. Additionally, it includes offering further guidance on applying interest withholding tax to interest payments made to Irish partnerships and foreign tax-transparent entities

On March 2024, the French Official Gazette published Decree No. 2024-274, introducing measures to eliminate double taxation of profits derived from corporate tax on foreign businesses. Among others the measure include (i) allowance of deduction from total net results for distributed dividends and participation products for France-based legal entities, regardless of profitability; (ii) clarifying that profits or income from sales for France-based entities, aren't considered when determining results for transferring shares of foreign entities, and (iii) France-based entities subject to corporate tax must justify including profits or positive income subtracted from the result of transferring or selling shares.

Portugal is updating the Nationality Law under Law 01/2024, which brings significant changes. The new provisions in the law include stricter national security and defense criteria, changes to the naturalization process for Sephardic Jews' descendants, the implementation of biometric verification for data authenticity, and a change in the calculation of the required period of legal residence for nationality acquisition by naturalization.

In addition, individuals applying for Portuguese nationality must have legally resided in Portugal for at least five years, including the time since they applied for a temporary residence permit, rather than just when it was issued. This is especially important for foreign citizens awaiting residence permit approvals, particularly those seeking an investment residence permit (ARI).Furthermore, the Portuguese Nationality Law establishes criteria for Portuguese origins and the circumstances under which non-nationals can acquire citizenship, emphasizing the importance of genuine ties and a deep connection with Portugal, its traditions, culture, and values.

In March 2023, business organizations in Canada called upon Parliament to include significant tax changes within the budget bill. The Canadian Chamber of Commerce advocated for amendments that would eliminate retroactive components of proposed digital services taxes, while electrical corporations requested an exemption from limits on interest expense deductions. The Senate is now considering Bill C-59, which proposes a 3% tax on large internet corporations retroactive to January 1, 2022.

The United States has previously criticized Canada's digital services tax for its impact on American firms. Furthermore, industry group Electricity Canada, pointed out how the bill's Excessive and Financing Expenses Limitation (EIFEL) provisions would disproportionately burden private companies that rely on foreign financing.

In march 2024, Belgium introduced a reduced value-added tax (VAT) rate of 6% to property renovation projects, in purpose to boost the investment in rental properties. Belgium Finance Minister Vincent Van Peteghem said that the reduced VAT rate, which is now applicable to demolishing old properties and constructing new private houses on the same site, will now also apply to rental oriented demolition and reconstruction projects. To qualify for the reduced rate, the property must not exceed 200 square meters and must be rented out as primary residences for a minimum of 15 years following reconstruction. In General, Belgium's VAT rate stands at 21%.

Australian treasurer Jim Chalmers, announced that the core minimum tax regulations will apply from January 1, 2024, pursuant to international standards. Australia seeks feedback on two sets of legislation implementing the 15% global minimum tax, aiming multinational corporations with annual global revenue exceeding EUR 750 million.

Additionally, the government is looking for feedback on how these laws interact with existing tax regulations, such as hybrid mismatch rules and controlled foreign company rules. The draft legislation is open for discussion until April 16th, 2024, and further changes to the current tax regulations are expected to come.

In the UK budget proposal, there's a plan to change a tax rule that benefits wealthy foreigners living in the country. The Chancellor of the Exchequer, Jeremy Hunt, talked about it during a meeting with the Parliament's Treasury Committee. As he stated in the meeting, the simplification of the tax system will include significant “Non-Doms” changes.
The current rule, known as the "non-domicile" tax loophole, allows wealthy foreigners to avoid paying tax on income they gain outside the UK. The proposed amendment includes the cancellation of this rule, and implement a tax regime where individuals are taxed on their foreign income once they have live in the UK for four years. .
According to Hunt, the "old" tax system is outdated and not efficient, and this new regulation is estimated to bring in about £2.7 billion per year for the UK government by 2028.

The European Commission is asking for feedback on the efficacy of the EU Directive (EU) 2017/1852 concerning tax dispute resolution mechanisms, aiming to facilitate the resolution of double taxation issues. Effective from July 2019, the Directive provisions a two-year deadline for Member States to resolve disputes arising from their tax agreements. In addition, it allows taxpayers to request an independent opinion or go to court if this deadline is missed.
The consultation, that took place in March 2024, aims to gather input on the process of filing complaints, the timeliness of authorities’ responses, and the effectiveness of resolving disputes within the two-year timeframe. .
This dispute resolution rule applies to both businesses and individuals. according to the commission, it's covers a wider range of issues compared to previous methods, extending beyond transfer pricing and profit attribution to permanent establishments.
The commission will review the feedback and evaluate the effectiveness of the law, to be followed by a report on its performance.

As of April 2024, Poland will reintroduce a 5% value-added tax (VAT) on basic foods, such as meat, dairy, and cereal products, according to an announcement from the Polish Finance Ministry. This decision making follows the implementation of a temporary 0% VAT rate on these essential items in early February 2022, aiming to assist customers in managing rising inflation.
The reimposing of the 5% VAT is supported by the preliminary statistical data indicating that January's inflation slowed to 3.9% year-on-year, the lowest since March 2021. The Ministry of Finance notes a significant decline in the annual growth rate of consumer prices for food and non-alcoholic beverages, down to 4.9% year-on-year. Moreover, the ministry predicts a downward trend for both inflation and the growth rate of food prices, supported by factors such as decreasing prices in global agricultural markets and a strong base effect from the previous year's substantial increase in food prices.

On March 2024, the French General Directorate of Public Finance updated the framework for income tax exemptions and deduction thresholds for specific professional expenses. The revision of thresholds provided with key benefits including meal allowances at the workplace and outside (7.30 euros and 10.10 euros respectively), business trip meal allowances (approximately 21 euros), accommodation and breakfast expenses for long-distance trips (74 euros to Paris and inner suburbs, 55 euros to other metropolitan areas), and employer contributions for meal voucher purchases (7.18 euros). Additionally, the doctrine outlines deduction thresholds, ranging from a minimum of 495 euros to a maximum of 14,171 euros, respectively, for the 10 percent standard deduction applicable to 2023 income.

In March 2024, the Finnish Parliament (Eduskunta) approved the consideration of a bill aimed at ratifying the Double Taxation Agreement (DTA) and its accompanying protocol with France. Signed on April 4, 2023, this DTA replaces the current 1970 DTA, introducing several key provisions, including: Prevention of double taxation on non-public service pensions,
Authorization for the source country to impose a 15 % withholding tax on portfolio dividends,
Shift the taxation methodology from the exemption method to the credit method and
Outline of rules regarding the taxation of permanent establishments (PEs).
The DTA complies with the OECD Model Tax Agreement, incorporating the minimum standards and recommendations outlined in the OECD base erosion and profit shifting (BEPS) project.

According to the nonpartisan Joint Committee on Taxation, the global tax deal, aiming to redistribute profits from major multinational corporations, could lead to an annual loss of US revenue ranging from $100 million to $4.4 billion.
This global deal, which was agreed upon by over 140 countries in 2021, comprises Pillar One, reallocating profits to market jurisdictions, and Pillar Two, establishing a 15% global minimum tax. Pillar Two has been enacted in numerous countries, but Pillar One remains pending.
The committee's analysis, released ahead of a House Ways and Means subcommittee hearing, presents three simulations, indicating a projecting of $1.4 billion loss. Concerns are presented over Pillar One provisions, with bipartisan opposition to the deal's aim of eliminating digital services taxes (DST), potentially impacting global GDP. DSTs, imposed by countries on large digital companies, prompted tariff threats from the US. Canada is proceeding with its DST plans, despite the agreement to delay implementation. The finalized treaty is expected this spring, with an extension granted to some countries to retain their DSTs until June.

In the past years, the shift from cash transactions to digital exchanges has rapidly progressed, signaling a potential transition to a cashless future. Greece, whilst facing economic challenges and tax evasion, has taken a significant step by implementing a ban on cash transactions exceeding 500 euros (approximately $540) to combat tax evasion. This policy carries substantial fines, potentially doubling the transaction amount. Concurrently, Greece has adopted a "point of sale everywhere" approach, ensuring that digital transactions generate receipts, with real-time data provided to the Independent Authority for Public Revenue. Assuming compliance and adequate enforcement resources, this policy is anticipated to significantly improve tax collection efficiency and effectiveness.
The increased usage of digital transactions, partly driven by the COVID-19 pandemic, may have enduring consequences. In a near cashless future, the pandemic could be remembered for fundamentally reshaping the global economy and providing a long-term solution to a major source of tax fraud.

Germany's ruling coalition is working on a stimulus package of approximately €7 billion ($7.6 billion) aiming to revive the country's economy. Chancellor Olaf Scholz's government aims to reduce the tax burden on companies and is working on securing parliamentary approval before the summer break. However, as the discussions are still in the early stages the package's value could change. The German Ministry of Finance has refrained from commenting on the plans.
The current proposed stimulus is about 0.16% of Germany's output this year. However, some economists suggest the country may need as much as €30 billion to overcome economic challenges, including high energy costs, exposure to the struggling Chinese market, and geopolitical tensions from Russia's war on Ukraine.
The Economy Minister, Robert Habeck, recently lowered the growth forecast for 2024 to 0.2%, citing challenges, including a court ruling from last year that overturned the coalition's budget strategies. The government is also seeking approval for a separate package, initially valued at €7 billion but now reduced to just over €3 billion, focusing on small- and medium-sized businesses. A meeting is scheduled for March 2024 to seek approval for this package in the upper house of parliament, Chancellor Scholz remains optimistic about the approval of the package, although in an altered version.

The Government of Spain is considering an alternative approach for energy companies where they can invest profits rather than paying a windfall tax. Energy Minister Teresa Ribera revealed in an interview plans for a new system, offering companies the choice to invest profits or contribute to the state through taxes. The government aims to implement this system in the upcoming weeks.
This temporary tax, which had its beginnings in 2023, as a relief measure for inflation, imposes a 1.2% levy on revenues of large energy companies. The mentioned tax has raised many concerns in the energy industry, and in response energy firms have demanded even more clarity on plans for the windfall tax. As a result, Repsol SA has announced plans to reduce investments in the country.
With the country's strong production of renewable resources, Spanish energy prices have fallen in recent days. However, companies have nevertheless experienced a significant increase in income as a result of the Russian invasion of Ukraine.

In March 2024, Belgium officially announced the Royal Decree No. 2022041540, as published in the Belgian Official Gazette. This decree will take effect starting from 2025 and outlines two key provisions: Firstly, it specifies the implementation of a zero percent income tax rate on specific sources of income such as pension income, other replacement income, and unemployment income for taxpayers earning up to 10,160 euros (US$11,031). Additionally, it details an increase in the basic deduction from 236 euros (US$256) to 237 euros (US$257).

The UK's annual finance bill, recently passed into law, includes global minimum tax changes, business tax breaks, and enhanced powers for the tax office. The global minimum tax, part of the OECD deal agreed by 140 countries so far, imposes a 15% tax on multinational enterprises. The law integrates OECD guidance supporting the application of the safe harbor, hence allowing companies to use country-by-country information, instead of accounting data to calculate the tax liability.
Additionally, the UK made the full expensing regime permanent, merged R&D tax breaks for large and small firms, and introduced a new credit for small R&D-intensive companies. Tax breaks for creative industries are now refundable expense credits. Other measures include extending grandfathering clauses for investment schemes and criminalizing continued promotion of tax avoidance schemes. In the course of March 2024, when Spring Budget will be presented by Chancellor of the Exchequer Hunt, further tax cut initiatives might be announced.

The Turkish Revenue Administration released Publication No. 504, clarifying the tax on income from selling property owned by an individual within five years of the purchase. The publication covers different topics, including, defining capital or commercial gains, taxation of capital gains from various property types, determining acquisition dates, filing electronic and paper tax declarations, 2023 income tax brackets and rules for claiming loss offset, deductions, and exemptions. This publication is useful for filing 2023 annual income tax returns.

A new Double Taxation Agreement (DTA) has been signed between the Turkish Revenue Administration and the state of Azerbaijan replacing the 1994 Double Taxation Agreement currently in force between the two countries. This agreement will enter into force after the approval of the DTA by the parliaments of both states. The main purpose of the new DTA is to create possibilities and favorable conditions for investors, including but not limited to cooperation in tax collection, taxing rights, and exchange of information.

Speakers at the Tax Foundation Europe seminar, voiced their concerns on possible tensions between Europe and the US over taxes on digital profits if the global tax deal's Pillar One faces delays. Pillar One governs the allocation of profits for tax purposes among the world's largest multinationals based on market presence jurisdictions, rather than headquarters. Stakeholders at the seminar voiced their concerns that the OECD's Pillar One proposal is uncertain, and in case it stalls, alternatively the revival of Digital Service Tax could prompt new US retaliation. As highlighted by European Commission, the EU’s priority is to increase tax revenue and balance their tax mix regime to meet growing public investments needs.

The Swedish Tax Agency on February 2024, following Statement No. 8-2785199, has clarified VAT rules for business transfers. The statement establishes that the transfer of business assets is not considered a delivery of goods or services unless deductible tax is owed or a refund is granted. Additionally, it highlights that the right of deduction is tax-exempt for outgoing transactions, regardless of tax status, and does not require deduction restrictions. Similarly, it clarifies that transferring a mixed-activity business is not considered a supply of goods or services under certain conditions. Lastly, it is stipulated that assets, aside from current assets, are exempt from tax liability if the taxable individual can demonstrate that the input tax was not entirely deductible at the time of acquisition.

The Austrian Federal Ministry of Finance clarified cross-border commuter tax exemptions in a recent decision posted online by the Federal Finance Court in February. The decision was presented about a case regarding an Austrian citizen working in Switzerland, who was sent to the U.S. by his employer to work for a month from March 28, 2021, to April 27, 2021. He claimed a tax exemption on the U.S. income. The tax office denied it, and the Austrian citizen appealed. The Federal Finance Court ruled that the exemption was not valid as the foreign activity in the U.S. did not last for more than one continuous month, as mandated by Austria's Income Tax Act. The one-month prerequisite would have been fulfilled on April 28, 2021, after the taxpayer's return.

Recently this month, Austrian Federal Ministry of Finance published online the Federal Finance Court Decision No. GZ. RV/7100381/2023, clarifying the taxation of losses from capital assets. The taxpayer, involved in share transactions, argued that the denial of loss deduction violated constitutional principles of equality and fairness.
The Tax Authority countered that the losses didn't qualify as extraordinary burdens under the law and in addition an income extrapolation error in the taxpayer's 2020 assessment was identified.
The Federal Finance Court sustained the Tax Authority's decision, stating that the losses weren't extraordinary burdens, the loss deduction exclusion was in line with constitutional principles, and the income tax assessment was revised to correct the income extrapolation error.
[Austria, Federal Ministry of Finance, 02/14/24]

A recent OECD report explains new rules that make it easier to simplify transfer prices proceedings for specific transactions under the 2021 global tax deal, called Amount B. These rules intent to simplify how companies value their transactions, particularly for basic marketing and distribution deals.
OECD stated: “This framework is expected to reduce transfer pricing disputes, compliance costs, and enhance tax certainty for tax administrations and taxpayers alike,” … adding “Low-capacity jurisdictions facing limited resources and data availability will especially benefit from the administrative simplification provided by Amount B.”.
The report and outlines situations in which a distributor falls under the scope of Amount B, including instances where the distributor engages in additional non-distribution activities, like manufacturing.
Furthermore, the report addresses the transfer pricing needs of "low-capacity" countries by simplifying the approach for certain distributors through Amount B rules. However, concerns arise about potential mismatches when one country opts for Amount B while the other does not. For example, OECD acknowledges India's reservations due to undefined terms and the risk of losing out on higher margins.
The Inclusive Framework plans to finalize the list of low-capacity jurisdictions by March 31, with the Amount B approach applicable from January 2025. The report's content is now part of the OECD Transfer Pricing Guidelines.

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