|
Hong Kong gazettes bill to introduce a new patent box regime under which qualifying income will be taxed at five percent.
The portion of eligible intellectual property income that will be taxed at the five percent rate will be determined in a manner that would be consistent with the "nexus approach" in BEPS Action 5, and will also take into account certain expenditures incurred by the previous owner of the intangible asset if conditions are met. The bill is subject to legislative amendments. The new regime is intended to have retrospective effect for financial years ending on or after April 1, 2023. The British Virgin Islands has issued a notice excluding the United Arab Emirates from the list of jurisdictions without a corporate income tax system.
The notice, issued by the International Tax Authority, pertains to the rules on economic substance. The notice states that entities should carefully consider the financial periods when claiming non-residence status in the United Arab Emirates. Bangladesh and Qatar signed a tax treaty on April 23.
Further information will be reported when available. Portugal is planning to reduce the corporate tax rate by two percentage points from 21 percent to 15 percent, per year, over three years.
The proposal is part of a government program, which was approved on April 10, 2024, and was, thereafter, submitted before Parliament. Further information will be provided when available. On 8 April 2024, the Treasury Law Amendment (Making Multinationals Pay Their Fair Share - Integrity and Transparency) Act, 2024 was enacted.
The newly classified general class investors will be subject to one of three new tests: fixed ratio test, group ratio test, or third party debt test. Financial entities will continue to be subject to the existing safe harbor test and worldwide gearing test or may choose the new third party debt test. The amendments apply to assessments for income years commencing on or after July 1, 2023, with the exception of new integrity rules (debt deduction creation rules) which apply in relation to assessments for income years starting on or after July 1, 2024. The International Monetary Fund (IMF) has released a Working Paper discussing the implications of the global minimum tax from the perspective of low-tax jurisdictions.
The paper argues that it is not possible to design a system that always guarantees generating exactly the bare minimum tax intended by the rules and motivates that this should not be the policy objective anyway. The paper notes that there is an opportunity to endorse a broader tax reform that can be beneficial for low-tax jurisdictions. The paper is authored by Shafik Hebous, Cory Hillier, and Andualem Mengistu. |
Archives
November 2025
|
COMTAX ABC/o Ekonomiforetaget Baehring Dahl AB
Berga Alle 3 25452 Helsingborg Sweden |
CONTACTTel.: +46 46 590 07 70
E-mail: support(@)comtaxit.com |
INFORMATION |
|
© COPYRIGHT 1985 - 2026 COMTAX AB. ALL RIGHTS RESERVED.