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.