Jordan and Switzerland signed a tax treaty on December 13.

The treaty is in line with the OECD’s Base Erosion and Profit Shifting (BEPS) recommendations, and includes an anti-abuse provision.
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The treaty also contains a provision on administrative assistance in line with the international standard for exchange of information upon request.

OECD has published public comments on the proposed changes to the Commentary on Article 5 of the OECD Model Tax Convention and its application to extractible natural resources.

Comments on the proposed changes were invited from stakeholders on November 16, 2023.
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The proposed changes result from the work by Working Party 1 on Tax Conventions and Related Questions - which is the subgroup of the OECD Committee on Fiscal Affairs in charge of the OECD Model Tax Convention – with a view to developing an alternative provision for inclusion in the Commentary on Article 5 of the OECD Model Tax Convention on activities in connection with the exploration and exploitation of extractible natural resources, together with related commentary.

The Belgian Presidency of the Council of the European Union has published a priority program for its six-month term starting January 1, 2024.

In the area of taxation, priority will be given to measures aiming to curb tax evasion, tax avoidance, aggressive tax planning, and harmful tax competition.
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Work will involve updating the EU’s list of non-cooperative jurisdictions, propelling both legislative and non-legislative initiatives to decrease compliance costs and the burden for cross-border investors, and tackling tax abuse related to withholding taxes.

Indonesia’s Finance Ministry has issued a regulation on the implementation of the arm's length principle in related-party transactions.

The regulation covers details on the application of the arm's length principle, transfer pricing documentation requirements, advance pricing agreements, and mutual agreement procedure, among other things.
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The regulation came into effect on December 29, 2023.   

France has published the Finance Law for 2024, which implements the Minimum Taxation Directive (2022/2523).

The Directive seeks to incorporate the OECD’s Pillar Two recommendations.

The new law introduces an additional tax on global profits subject to an effective tax rate lower than 15%. The additional tax takes the form of either a domestic minimum top-up tax (DMTT); an income inclusion rule (IIR); or an undertaxed profits rule (UTPR).

The new rules apply to large groups with an annual revenue of EUR 750 million or more.

The IIR and DMTT apply to fiscal years commencing on or after December 31, 2023. The UTPR applies to fiscal years commencing on or after December 31, 2024.

On January 9, 2024, the OECD conducted a webinar on the economic impact assessment of the Global Minimum Tax.

The Global Minimum Tax (GMT) introduces significant changes to the international tax architecture and thereby to the taxation of large multinational enterprises.
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In the webinar, the OECD discussed the latest results on the impacts of the GMT on the taxation of MNEs. The analysis uses new and unique data on MNE worldwide activity and comprehensive estimates of global low-taxed profit to estimate the impact of the GMT. It also extends previous OECD impact assessment work by incorporating a revised methodology that captures the final design of the GMT.

Senegal has committed to implement the international Standard for Automatic Exchange of Financial Account Information in Tax Matters (AEOI) by September 2025.
“We welcome Senegal’s decision to join the other jurisdictions engaged in the automatic exchange of information, as this will advance the country’s fight against tax evasion and other illicit financial flows and might ultimately benefit its domestic resource mobilisation,” said Gaël Perraud, Chair of the Global Forum.
​The Global Forum will monitor Senegal’s progress in delivering its commitment to start exchanging automatically by September 2025 and updates will be provided to the Global Forum members and the G20. The Global Forum Secretariat will assist Senegal in implementing the AEOI Standard and in addressing any challenges that may arise.

The implementation of Pillar Two in the European Union through the Minimum Taxation Directive became effective on January 1, 2024.

The Directive introduces a minimum effective tax rate of 15% for in-scope groups.
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The Directive was published in the Official Journal of the European Union on December 22, 2022, and entered into force on December 23, 2022.

On December 13, 2023, the amending protocol to the Bulgaria-Germany tax treaty entered into force.

The amending protocol was signed on July 21, 2022.
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The protocol generally applies from January 1, 2024, for withholding and other taxes.

On December 30, 2023, the tax treaty between France and Greece entered into force.

The treaty generally applies from January 1, 2024, for withholding and other taxes.
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From this date, the new treaty replaced the existing tax treaty.