Egypt and Qatar signed a tax treaty on 27 February 2023.
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Further details about the treaty would be reported as and when they occur.

On 28 February 2023, the Government of Andorra announced that it has signed a tax treaty with Iceland.
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Further details about the treaty would be reported as and when they occur.

The OECD will hold a public consultation meeting on compliance and tax certainty aspects of global minimum tax on March 16.

This public consultation meeting will discuss the input provided to assist members of the Inclusive Framework in completing the work relating to those aspects and preserve consistent and coordinated outcomes for MNEs while minimizing compliance burdens and avoiding the risk of double taxation.

Registration is open until March 10, 2023.

On 22 February 2023, the Financial Secretary of Hong Kong delivered the country’s 2023/24 Budget.

In the Budget, the Financial Secretary revealed that the government would soon launch a public consultation on the implementation of the GloBE Rules.
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The Budget also reveals that the government is considering to implement a domestic minimum top-up tax starting from 2025.

The Council today decided to add British Virgin Islands, Costa Rica, Marshall Islands and Russia to the EU list of non-cooperative jurisdictions for tax purposes.

With these additions, the EU list now consists of 16 jurisdictions.
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Elisabeth Svantesson, Minister for Finance of Sweden, said: “Today, we decided to add four jurisdictions to the EU list of non-cooperative jurisdictions for tax purposes: British Virgin Islands, Costa Rica, Marshall Islands and Russia. We ask all listed countries to improve their legal framework and to work towards compliance with international standards in taxation. At the same time, I warmly congratulate North Macedonia, Barbados, Jamaica and Uruguay as they successfully fulfilled their commitments and could be removed from the state of play document.”

The Australian Taxation Office (ATO) has acknowledged the announcement by Ampol Limited (Ampol) that it has reached a settlement with the ATO for $157 million.

ATO Deputy Commissioner Rebecca Saint welcomed the ASX announcement from Ampol, noting the settlement shows the ATO’s commitment to working with multinationals to ensure full compliance with the Australian tax regime.
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The settlement resolves the dispute for past years back to 2014 for $157 million. Importantly, it also locks in the tax outcomes of the arrangement out to 2033. The settlement covers the transfer pricing outcomes of refined products and crude oil between Ampol Singapore and Ampol Australia as well as how Australia’s controlled foreign companies regime will apply to the profits of Ampol Singapore.

Singapore will implement the Global Anti-Base Erosion (GloBE) Rules, that is, Income Inclusion Rule and Undertaxed Profits Rule, and Domestic Top-up Tax from January 1, 2025.

The announcement was a part of the country’s 2023 Budget, which finance minister Lawrence Wong, presented before Parliament today.

Delivering the Budget, the finance minister said that the government would implement a Domestic Top-up Tax, which will top up the MNE groups’ effective tax rate in Singapore to 15 percent. “At the same time, we will review and update our broader suite of industry development schemes to ensure that Singapore remains competitive in attracting and retaining investments,” the minister said.
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Wong told the Parliament that the government will continue to monitor international developments. “If there are additional delays, we will adjust our implementation timeline. We will continue to engage companies and give them sufficient notice, well ahead of any changes to our tax rules or schemes,” the minister said.

Japan and Algeria signed a tax treaty on February 7.

The tax treaty provides for a withholding tax rate of five percent for dividends for holding of at least 25 percent of shares for one year. The rate would be ten percent in all other cases.
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Royalties and interest payments would be subject to a withholding tax rate of ten percent and seven percent, respectively.

Cameroon and Czech Republic signed a tax treaty on February 7.

The treaty is the first of its kind for both countries. It will enter into force after the ratification instruments are exchanged between both countries.
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The details of the treaty are not currently available.

UK government has published guidance on reportable cross-border arrangements under the country’s mandatory disclosure rules (MDR).

The deadline for reporting an arrangement that was made available from 25 June 2018 but was not reportable under DAC6 is 24 September 2023.
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The rules will come into effect from March 28, 2023.

The OECD has released technical guidance to assist governments with implementation of the 15 percent global minimum corporate tax rate.

Guidance is included on the recognition of the United States’ minimum tax under the GloBE Rules and on the design of Qualified Domestic Minimum Top-up Taxes. The scope, operation and transitional elements of the GloBE Rules are also included in the guidance.
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The guidance will be incorporated into a revised version of the Commentary that will be released later this year.

The OECD has published a Manual on the Handling of Multilateral Mutual Agreement Procedures (MAPs) and Advance Pricing Arrangements (APAs), intended to be abbreviated as the MoMA.

The MoMA is intended as a guide to multilateral MAP and APA processes from both a legal and procedural perspective and suggests different approaches based on the practices of jurisdictions, without imposing a set of binding rules.

The MoMA allows tax administrations to explore whether implementation of these procedures is appropriate considering the circumstances of their own MAP and APA programs and to consider whether the guidance therein may be incorporated in their domestic guidance on MAP or APA processes to provide additional clarity. The MoMA also outlines the actions and cooperation expected from taxpayers to allow tax administrations to consider MAP and APA cases multilaterally. The MoMA is the result of the work done within the FTA MAP Forum.