Tunisia has deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting.
The Convention will enter into force on November 1, 2023, for Tunisia.
Around 650 additional tax treaties will be modified once the BEPS Convention will have been ratified by all Signatories.
India’s tax authority has announced that the Boards for Advance Rulings have been operationalized in Delhi and Mumbai.
A non-resident investor can obtain certainty on its liability towards income tax even before undertaking the investment in India. Resident companies may also obtain a tax ruling on the taxability of a transaction and avoid long-drawn litigation.
“Creation of mechanisms like the Board for Advance Rulings is a step in this direction,” it said.
The Cabinet Secretary of the National Treasury of Kenya is seeking public input on draft tax treaties with Belgium and Egypt.
Comments on the draft tax treaties with Belgium and Egypt must be received by September 11 and September 13, respectively.
Curacao will apply a reduced corporate income tax rate of 15 percent to companies earning below ANG 500,000.
The corporate tax rate of 22 percent will continue to apply to companies earning over ANG 500,000.
The changes apply retroactively from January 1, 2023.
The General Court of the European Union has rejected challenge to EU Directive 2022/2523 of 14 December 2022, on ensuring a global minimum taxation.
The General Court dismissed the challenge as “manifestly inadmissible,” in view of Article 263 of the Treaty on the Functioning of the European Union (TFEU).
Under that article, proceedings for annulment must be instituted within two months of the publication of the contested measure, or of its notification to the plaintiff, or, in the absence thereof, of the day on which it came to the knowledge of the latter, as the case may be.
The General Court said the applicants have not pleaded the existence of unforeseeable circumstances to allow the Court to vary the time-limit in question.
Australian government has announced key measures to tackle tax adviser misconduct.
The tax reforms package cover three priority areas: strengthening the integrity of the tax system, increasing the regulatory powers, and strengthening regulatory arrangements to ensure they are fit for purpose.
The government will remove limitations in the tax secrecy laws. The government is seeking to strengthen existing regulatory frameworks which it feels are not fit for purpose.
The United Nations (UN) Secretary General has published an advance, unedited report on promoting effective and inclusive international tax cooperation.
The report analyses existing arrangements in international tax cooperation, identifies additional options to make such cooperation fully inclusive and more effective, and outlines potential next steps. It utilizes a definition, derived from the inputs and analysis, of inclusiveness and effectiveness of international tax cooperation in substantive and procedural terms.
The report finds that enhancing the UN role in tax-norm shaping and rule setting, fully taking into account existing multilateral and international arrangements, appears the most viable path for making international tax cooperation fully inclusive and more effective.
UK tax authority has published draft tax law aimed at imposing tougher legal consequences on promoters of tax avoidance schemes.
The government is seeking to introduce a new criminal offence to apply to promoters of tax avoidance who fail to comply with a Stop Notice under the Promoters of Tax Avoidance Schemes regime issued in respect of tax avoidance arrangements.
Comments on the draft tax law must be received by September 12.
Denmark has terminated its tax treaty with Russia.
The treaty was terminated through Notice No. 27/2023 dated June 19, 2023.
The tax treaty will cease to have effect on January 1, 2024.
The US Internal Revenue Service is inviting public input on improvements to certain post-filing alternative dispute resolution (ADR) programs.
The IRS is interested in suggestions to improve the administration of these ADR programs and in proposals for other approaches to ADR that can increase the use and efficacy of ADR in the resolution of tax disputes. The IRS welcomes comments on all aspects of alternative dispute resolutions practices to help inform IRS policies for improving taxpayer service and resolving issues and cases fairly and expeditiously.
Comments must be received by August 25.
South African Revenue Service is seeking public input on draft tax bills.
The 2023 draft Taxation Laws Amendment Bill contains the necessary legislative amendments required to implement the more complex tax announcements made in the 2023 Budget Review relating to R&D tax incentive, clarifying anti-avoidance rules dealing with third-party backed shares, and refining the participation exemption for the sale of shares in foreign companies.
The 2023 draft Tax Administration Laws Amendment Bill contains legislative amendments dealing with tax administration such as APAs.
Comments must be received by August 31.
The OECD has issued administrative guidance on the global minimum tax rules.
Detailed administrative guidance has been published on currency conversion rules, the substance based income exclusion, and further guidance on the treatment of tax credits.
The two new safe harbours included in the package are a permanent safe harbour for jurisdictions that introduce a Qualified Domestic Minimum Top-up Tax (QDMTT), and a transitional UTPR Safe Harbour, which provides the UPE Jurisdiction with relief from the application of the UTPR for fiscal years commencing on or before the end of 2025.
Norwegian government has terminated tax treaties with Barbados, Curacao, Jamaica, Sierra Leone, and Trinidad and Tobago.
The terminations were published in the Royal Decree on June 9.
The terminations will take effect on January 1, 2024.
The OECD is inviting public input on its two-pillar solution to address digital economy taxation.
The OECD is seeking comments on the design elements of Amount B. Input is requested on ensuring an appropriate balance between a quantitative and qualitative approach in identifying baseline distribution activities.
Comments must be received by September 1, 2023.
Ireland is consulting stakeholders on measures that would prevent double non-taxation arising from outbound payments to low or no tax jurisdictions.
The legislative measures would include withholding taxes on, or non-deductibility of, outbound payments. In the case of dividends, measures would include withholding taxes as dividends are non-deductible, to be completed by March 31, 2024.
Comments must be received by August 8.