The Australian Taxation Office (ATO) has been successful in the Full Federal Court decision of Singapore Telecom Australian Investments PTY Limited (SingTel) vs Commissioner of Taxation.

The decision confirms SingTel claimed a transfer pricing benefit for deductions based on interest paid on loans between two of its subsidiaries regarding its acquisition of Optus in 2002.
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Deputy Commissioner Rebecca Saint said this decision is another substantial win for the ATO and the Tax Avoidance Taskforce.

On March 21, 2024, the Australian Treasury released exposure draft legislation to implement a global and domestic minimum corporate tax rate of 15 percent.

The draft legislation is part of a global effort to prevent a race to the bottom on corporate income tax.

The legislation ensures Australia will be among the lead jurisdictions implementing these global and domestic minimum taxes as a key part of the OECD/G20 Two‑Pillar Solution that was agreed in 2021.
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Comments on the draft law must be received by April 16.

Members of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) continue to make steady progress in the implementation of the BEPS package to tackle international tax avoidance, as the OECD releases the latest peer review report assessing jurisdictions' efforts to prevent tax treaty shopping and other forms of treaty abuse under Action 6 of the OECD/G20 BEPS Project.

A revised peer review document forming the basis of the assessment of the BEPS Action 6 minimum standard was also released today.
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The sixth peer review report on the implementation of the Action 6 minimum standard on treaty shopping, which includes data on tax treaties concluded by jurisdictions that were members of the Inclusive Framework on 31 May 2023, reveals that most agreements concluded between the members of the Inclusive Framework are either already compliant with the Action 6 minimum standard or will shortly come into compliance.

On March 11, 2024, US President Joe Biden submitted the country’s 2025 Budget, including key international tax measures.

The Budget proposes to raise the corporate income tax rate to 28 percent, the corporate alternative minimum tax rate on billion-dollar corporations from 15 percent to 21 percent, and the tax rate on US multinationals’ foreign earnings from 10.5 percent to 21 percent.
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The Budget also seeks to reform international taxation by revising the global minimum tax regime, limiting inversions, and making related reforms; and adopting the undertaxed profits rule. It also seeks to revise the rules that allocate Subpart F income and GILTI between taxpayers to ensure that Subpart F income and GILTI are fully taxed, among other proposals.

The OECD organized a transfer pricing capacity building workshop for representatives from 13 West African countries’ tax administrations, and from the Economic Community of West African States (ECOWAS) and the West African Economic and Monetary Union (WAEMU) Commissions.
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The workshop was organized between March 5-7, 2024, in Ghana, as part of the Fiscal Transition Support Programme (FTSP) in West Africa.

The workshop is the fifth in a four-year capacity building cycle that has created a network of some thirty West African transfer pricing experts. It follows on from the capacity building workshops held in Dakar and Lomé in 2023, and deals with the approaches that developing countries can consider adopting to prevent tax disputes between states, thereby strengthening legal certainty for businesses and improving the investment climate.

The tax treaty between Croatia and Egypt entered into force on March 1, 2024.

The treaty applies from January 1, 2025, for withholding taxes.

Further details will be provided when available.

Bahrain and Hong Kong signed a tax treaty on March 3, 2024, in Manama.
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Further details will be provided when available.

The OECD has published public comments on a draft toolkit to support developing countries in addressing base erosion and profit shifting risks when pricing minerals (lithium).

The toolkit is designed to support developing countries in addressing the transfer pricing challenges faced when pricing minerals.
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The toolkit applies this transfer pricing framework as documented in Determining the Price of Minerals: A Transfer Pricing Framework to a specific mineral (lithium).