The South African Revenue Service has published guidelines regarding the completion of the Withholding Tax on Royalties return, how to make payment on e-Filing, and apply for a refund using the Rev16 form.

Guidance is included on completion on withholding tax on royalties return, declaration, payment of withholding tax on royalties, and refund of withholding tax on royalties, among other things.
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The guide was published on August 23.

Bermuda’s Finance Ministry is consulting stakeholders on the country's new corporate income tax regime.

The Corporate Income Tax Act,  2023 was enacted in December 2023 and provides that Bermuda Constituent Entity Groups, comprised of one or more Bermuda Constituent Entities of an “In Scope” MNE Group, are subject to Bermuda corporate income tax with respect to fiscal years beginning on or after January 1, 2025.

The consultation paper is intended to provide Bermuda stakeholders with a preliminary, high-level summary of the proposed taxpayer compliance framework and to obtain public feedback on the proposals.
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Comments must be received by September 5.

The Indian Supreme Court has dismissed a review petition filed in the controversial most-favored-nation (MFN) judgment delivered by it last year in Assessing Officer (International Taxation) vs. M/s Nestle SA.

The controversial ruling concerned MFN clauses in India’s tax treaties with countries including France, the Netherlands and Switzerland. The tax authority had refused to accept the taxpayers’ request for invoking the MFN clauses in the tax treaties, under which a reduced withholding tax rate were to be applied.

The top court, however, found in favour of the tax authority. The court accepted the tax authority’s argument that the MFN clauses could not be invoked because the Indian government did not issue any notification to activate the MFN clause – a prerequisite under Indian domestic legal framework.

Subsequently, the taxpayer filed a petition asking the court to review its own judgment.
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In a short order dated August 6, 2024, the court said that there are no grounds for review and dismissed the review petition.

Ireland’s tax authority has published a new manual setting out an overview of the Administration of Pillar Two rules.

In addition, the tax authority has published an update to existing guidance on the operation of the Pillar Two rules, along with the detailed correlation table which cross references the legislation contained within Part 4A of the TCA 1997 with:
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• the relevant article of the EU Minimum Tax Directive,
• the relevant article of the OECD Model Rules,
• OECD Commentary, where relevant, and
• OECD Administrative Guidance, where relevant.

On 6 August 2024, Ecuador and the United Kingdom signed a tax treaty.
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Further details would be reported when available.

Australian tax authority is setting up a special purpose working group to support consultation on the implementation of the global and domestic minimum tax in Australia for multinational businesses.

Through consultation, the working group will seek feedback on administrative aspects of the implementation of the new measure.
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Expressions of interest in this regard may be submitted by August 9.

Argentina has removed five tax jurisdictions from the list of non-cooperative tax jurisdictions maintained under Article 24 of the country’s Income Tax Regulations.

The following five tax jurisdictions have been removed: Benin, Burkina Faso, Papua New Guinea, Rwanda, and Vietnam.

Under Article 19 of the Income Tax Regulations, a “non-cooperative” tax jurisdiction is a country or jurisdiction that does not have a tax treaty (with an elaborate exchange information clause) or an information exchange agreement with Argentina.

As per the government, the five countries removed from the list are now in a position to exchange tax information with Argentina.
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The updated list was gazetted on July 11.

India has withdrawn its two percent Google Tax in the country’s latest Budget.

The latest Budget, announced on July 23, states that the Google Tax (known as equalization levy) shall not apply from August 1, 2024.

The two percent Google Tax applied to consideration received for e-commerce supply of goods or services by non-residents. India was one of the first countries to adopt a Google Tax in the form of a unilateral domestic tax measure to tackle digital economy taxation.

Last month, the OECD said that it is nearing international agreement on Pillar One, which would require countries to withdraw unilateral digital tax measures. It is not clear if India will sign this international agreement in view of the reservations expressed by the Indian government to the OECD.

Bermuda has tabled in Parliament the Corporate Income Tax Agency Bill, 2024.

The bill, tabled on July 12, 2024, is aimed at creating a Corporate Income Tax Agency (CITA) to administers the country’s corporate income tax regime.

In December last year, Bermuda enacted the Corporate Income Tax Act 2023, imposing a 15 percent corporate income tax rate on the Bermuda business of multinational groups that are “in scope” of the Pillar Two Rules developed by the OECD.
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The agency’s structure will allow for a Board of Directors to ensure effective governance and oversight, and a Chief Executive Officer and staff will be responsible for effective and appropriate tax administration and enforcement.

The US Ways and Means Republicans have called on the Biden Administration to take swift and strong steps against Canada’s decision to impose a discriminatory digital services tax (DST) on US businesses.

In their July 11 letter to United States Trade Representative (USTR), Ambassador Katherine Tai, Republicans on the US Ways and Means Committee urged the Biden Administration to utilize authorities under Section 301 of the Trade Act to send a strong response to Canada, given the threat the DST poses to US businesses.
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The letter was signed by every Republican on the Committee.

Statutory corporate tax rates are stabilizing worldwide after a lengthy period of falling rates, according to new OECD data.

The 2024 edition of OECD Corporate Tax Statistics shows that average statutory corporate income tax rates have remained steady at 21.1 percent over the past three years. This follows a two-decade period that saw average statutory corporate income tax rates decline from 28 percent in 2000 to 21.1 percent in 2021.

Anticipation of the new global minimum tax, agreed by more than 140 members of the Inclusive Framework on BEPS, may have contributed to the recent stabilization, according to the report.
The latest edition of Corporate Tax Statistics also points to a stabilization of certain tax incentives designed to attract mobile intangible assets and their related income.

UK Government has published guidance on preparing for the two new taxes introduced in the UK as part of the international response to the challenges of digitalization.

The government had announced two new taxes as part of the UK adoption of the OECD Pillar Two rules: the Multinational Top-up Tax (MTT); and the Domestic Top-up Tax (DTT). These will apply to accounting periods that begin on or after December 31, 2023.

MTT will require all groups with both UK and non-UK entities and sufficient consolidated revenue to register with the tax authority. A charge may arise on UK parent members within such a group, where a UK parent member has an interest in an entity in a non-UK jurisdiction, and the group’s profits arising in that jurisdiction are taxed below the minimum rate of 15 percent.

DTT will require all groups with UK entities and sufficient consolidated revenue to register with the tax authority. A charge may arise on UK members within a domestic or multinational enterprise group where UK profits are taxed below the minimum rate of 15 percent.
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Groups will have UK obligations even if they do not have MTT or DTT liabilities. These obligations will apply to both UK-headed and non-UK headed groups irrespective of whether the jurisdiction of the Ultimate Parent Entity implements Pillar Two.

The OECD has published for stakeholders’ comments a draft version of the XML Schema and User Guide developed as part of the OECD’s work on formulating the Global Anti-Base Erosion (GloBE) model tax rules.

The draft version of the GIR XML Schema and User Guide is designed to both facilitate domestic GIR filings, wherever appropriate, and to be the technical format for exchanging GIR information between tax administrations.
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Comments must be received by August 19.

The Nigerian Government has approved a new withholding tax regime as part of the ongoing fiscal policy and tax reforms.

The new withholding tax regime incorporates tax measures to curb tax evasion and minimize tax avoidance. It contains changes to reflect emerging issues and adopt global best practices.
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The new withholding tax regime provides clarity on the timing of deduction and sets out definitions of key terms.

The Bahamas’ Finance Ministry has published guidance on the mutual agreement procedure (MAP) framework set out in the Tax Information Exchange Agreement between The Bahamas and Japan.

The guidance discusses several aspects of the MAP framework including who can request a MAP, how to initiate a MAP request, the processing of MAP requests, and implementation of the agreement.
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The guidance states that the Competent Authority will strive to resolve cases in a timely manner and keep the taxpayer informed of the status of their request on an ongoing basis.