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Approved Changes (8)

Bhutan

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Bhutan Extends Fiscal Measures for COVID-19 Including BIT/CIT Deferral

Bhutan's Department of Revenue and Customs has published a Notification dated 30 December 2021 on the extension of fiscal measures for COVID-19. One of the main measures is the deferral of business income tax (BIT) and corporate income tax (CIT) payment for tour operators, hotels, and airline companies. This provides that such qualifying businesses may defer payment of BIT/CIT for the income year 2019 until 30 June 2022, which must be applied for with the Regional Revenue & Customs Office where they are registered as taxpayers.

01-24-2022

Cameroon

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Cameroon Finance Law for 2022 Published Including Several Tax Measures

Cameroon's Ministry of Finance has published the Finance Law for 2022 (Law No. 2021/026 of 16 December 2021). The Ministry has also published Circular no. 00000456/C/MINFI Of 30 December 2021 on the instructions for the execution of the Finance Law for 2022, including an overview of the main tax measures. Some of the measures include:

  • A tax on money transfer operations ("Money Transfer Tax") is established at the rate of 0.2% of the amount transferred or withdrawn, which covers:
    • money transfer operations carried out by any means or technical support that leaves a trace, notably, by electronic means, mobile telephone, telegraph or by telex or fax, with the exception of simple bank transfers and transfers for the payment of taxes, duties, or other levies; and
    • cash withdrawal operations following a money transfer made to financial institutions or telephone companies;
  • The reduced rate of the special income tax (Taxe Spéciale sur le Revenue - TSR) has been reduced from 5% to 3%, including on:
    • remunerations within the framework of public procurement for which the successful tenderers are not domiciled in Cameroon;
    • remunerations for services of all kinds provided to oil companies during the research and development phases;
    • remuneration paid by maritime transport companies governed by Cameroonian law for the rental and charter of vessels, the rental of spaces on foreign vessels, and for commissions paid to port agents abroad; and
    • commissions paid to money transfer companies located abroad;
  • An exemption from TSR is provided for the benefit of holders of petroleum contracts and their subcontractors in the research and development phase with respect to remuneration for assistance, rental of equipment and material, and all other services rendered to them in connection with oil operations by foreign services providers, provided that the foreign service providers do not have a permanent establishment in Cameroon and provide the service at cost price (may also opt for the 3% reduced rate);
  • The rate of registration duty has been reviewed (revised) downwards from 15% to 5% on any agreement aimed at enabling an entity to carry out an activity carried out by a previous holder, even where the said agreement concluded with the latter or their successors in title is not accompanied by a transfer of customers;
  • The conditions for the deductibility of losses relating to bad debts of companies have been relaxed by providing an exemption from the obligation to justify the exhaustion of the means of recovery for smaller debts below 500,000 CFA franc that have been provisioned over a minimum period of 5 years;
  • A specific tax regime is established for non-profit organizations (entities that do not carry out economic activity for the purpose of making a gain for their members and/or do not compete within the commercial sector), including:
    • the establishment of an exemption from the payment of business licenses, company tax, and land tax by such entities, although they remain liable, to VAT, registration fees and stamp duties, income tax on investments in movable capital, and withholding taxes and levies collected from third parties (subject to any legal exemptions that may be provided for); and
    • for non-profit organizations carrying out commercial activities, separate accounts must be kept and a reduced corporate tax rate of 15% is provided on said activities together with a preferential deposit (installment) rate of 1.1% on monthly turnover (1% rate with 10% additional council tax);
  • The tax rate on dividends, interest on bonds with a maturity of less than five years, and other proceeds from stocks listed on the Central African Stock exchange is set at 10%;
  • To strengthen fiscal measures to promote youth employment, an exemption is provided from any tax levy on allowances paid by companies to young graduates as part of a pre-employment internship;
  • Full deductibility is established, without any cap, for donations and gifts granted by companies as part of the construction and development plan for economically stricken regions;
  • The requirement for an exemption certificate is removed for the VAT exemptions provided for in Articles 122 and 128 of the General Tax Code, including the VAT exemptions for the agriculture sector and VAT exemptions for certain real estate transactions, international traffic transactions, tuition and boarding fees, essential goods, and several others;
  • Measures to revive the banana sector are introduced, including:
    • for banana sector companies located in Economic Damage Zones (EDZs), the same tax facilities already granted to new companies investing in EDZs are granted for a period of 7 years, including exemptions from:
      • business license tax;
      • VAT on purchases of goods and services and inputs;
      • registration fees on real estate transfers;
      • land property tax;
      • company tax, including monthly installments and minimum collection; and
      • employer contributions on salaries paid to staff;
    • for banana sector companies not located in an EDZ, a 50% reduction in the rate of installments and minimum collection of company tax, as well as the calculation of installments and minimum collection of company tax on the Free on Board (FOB) value for a period of 7 years;
  • A temporary and optional mechanism is established to neutralize the tax consequences of the free revaluation of a company's fixed assets, carried out in application of the provisions of the Uniform Act relating to accounting law and financial information and the OHADA accounting system;
  • Measures to promote tax compliance are introduced, including:
    • a discharge of 10% on rents received from non-professional tenants;
    • for the 2022 fiscal year, taxpayers who spontaneously adjust their tax situation with regard to the tax on property income and the tax on land ownership are exempt from tax reminders as well as penalties over the period;
    • an obligation is introduced to keep separate accounts for companies that, in addition to their main activity, carry out on an ancillary basis another activity that can be the subject of an independent operation, and further, such companies are required to pay, as appropriate, specific taxes for the ancillary activity; and

a reduced penalty rate of 15% is established, instead of the common law rates of 30%, or even 100% or 150%, in the event of insufficiencies, omissions, or concealments that affect the base or the elements of taxation;

Several customs amendments are introduced, including the total exemption from customs duties and taxes on the importation of goods intended for priority sectors of agriculture, animal husbandry, human and animal health, and extensive local wood processing activities.

The measures of the Finance Law for 2022 generally apply from 1 January 2022.

01-24-2022

European Union-Austria-Belgium-Bulgaria-Croatia-Czech Republic-Denmark-Estonia-Finland-Greece-Germany-Hungary-Ireland-Italy-Latvia-Luxembourg-Malta-Netherlands-Poland-Portugal-Romania-Slovenia-Spain-Sweden

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Update - European Commission Extends Waiver of Customs Duties and VAT on the Import of Medical Equipment until June 2022 for 23 Member States

As previously reported, The European Commission extended to 30 June 2022 the waiver of customs duties and VAT on the import of medical and protective equipment from non-EU (third) countries. The waiver was first introduced in April 2020 in response to the COVID-19 pandemic and was previously extended to 31 December 2021. However, the decision for the extension of the waiver to 30 June 2022 is limited to 23 of the 27 EU Member States, including: Austria, Belgium, Bulgaria, Croatia, the Czech Republic, Denmark, Estonia, Finland, Greece, Germany, Hungary, Ireland, Italy, Latvia, Luxembourg, Malta, the Netherlands, Poland, Portugal, Romania, Slovenia, Spain, and Sweden.

EU Member States for which the waiver no longer applies from 1 January 2022 include Cyprus, France, Lithuania, and the Slovak Republic.

01-24-2022

Germany-European Union

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AG Opinions Issued Finding that German Capital Income Tax Refund Conditions Violate EU Law

On 20 January 2022, an opinion was issued from Advocate General (AG) Collins of the Court of Justice of the EU (CJEU) for a preliminary ruling on whether German refund (reimbursement) conditions for withholding tax on certain capital income violate EU Law. The case and opinion are summarized as follows.

Introduction

The request for a preliminary ruling from the Finanzgericht Köln (Finance Court, Cologne, Germany) concerns the compatibility, with the EU rules governing the free movement of capital, of the conditions under which German tax legislation permits non-resident companies to obtain the reimbursement of a withholding tax on income from capital consisting of dividends from minority shareholdings in companies established in Germany. The request arises in the context of a challenge by ACC Silicones Ltd to the refusal by the Bundeszentralamt für Steuern (Federal Central Tax Office, Germany) to allow claims for the reimbursement of that tax, which had been withheld and paid for the years 2006 to 2008 inclusive.

Referring court queries

In the first place, the referring court queries whether the fact that reimbursement of withheld tax on income from capital to companies resident abroad that have an equity holding of less than 10% or 15% in a resident company is subject to stricter conditions than reimbursement of that tax to resident companies that have an equivalent equity holding in a resident company is contrary to Article 63 TFEU. Indeed, under point 5 of the second sentence of Paragraph 32(5) of the KStG, withheld tax is reimbursed to foreign companies only if they, or their direct or indirect shareholders, cannot offset it or deduct it as an operating cost or as work-related outgoings. The referring court also points out that the requirement, laid down in the fifth sentence of Paragraph 32(5) of the KStG, that proof of the foregoing must be provided in the form of a certificate from the foreign tax authorities does not apply to the reimbursement of tax on income from capital to resident companies. It is unsure whether those rules, which, according to it, constitute an interference with the free movement of capital, are justified in the light of Article 65(1)(a) TFEU and of the criteria established by the Court in, inter alia, the judgment of 8 November 2007, Amurta (C 379/05, EU:C:2007:655).

In the second place, in the event that the abovementioned national rules are considered to be compatible with the free movement of capital, the referring court queries whether the requirement of proof imposed by the fifth sentence of Paragraph 32(5) of the KStG on companies resident abroad receiving dividends from 'free-float shares' complies with the principles of proportionality and effectiveness where, as in the present case, it is practically impossible for those companies to provide such proof.

AG Conclusion

In the opinion, AG Collins concludes that the CJEU should answer the first question referred for a preliminary ruling as follows:

Article 63 TFEU precludes a national tax provision, such as that at issue in the main proceedings, which, for the purposes of the reimbursement of tax on income from capital, requires a non-resident company which receives dividends from equity holdings and does not meet the minimum equity holding threshold laid down in Article 3(1)(a) of Council Directive 90/435/EEC of 23 July 1990 on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States, as amended by Council Directive 2003/123/EC of 22 December 2003, to prove, by means of a certificate from the foreign tax administration, that the tax cannot be offset by a shareholder with a direct or indirect equity holding in that company or be deducted by the latter company or by a shareholder with a direct or indirect equity holding in it as an operating cost or as work-related outgoings in the State of residence, in the case where such proof is not required, for the purposes of the reimbursement of tax on income from capital, from a company with the same level of equity holding which is resident in national territory. In order to be compatible with Article 63 TFEU, such a national provision must reimburse the tax on income from capital to the recipient non-resident company to the extent that the tax cannot be offset in the State of residence pursuant to any applicable convention for the avoidance of double taxation. Where only partial set-off is possible in the State of residence, the source State must reimburse the difference.

Considering the answer to the first question, no answer is given (needed) regarding the second question.

01-24-2022

Ireland

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Ireland Extends and Clarifies COVID Support Schemes Including the Tax Debt Warehousing Scheme

Ireland's Department of Finance issued a release on 21 January 2022 regarding the government's agreement to extend and clarify certain COVID support schemes, including the Employment Wage Subsidy Scheme (EWSS), the Covid Restrictions Support Scheme (CRSS), and the Tax Debt Warehousing Scheme.

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Minister Donohoe announces changes to economic supports for businesses most impacted by recent public health restrictions

The Minister for Finance, Paschal Donohoe has today (Friday) announced changes to a number of the COVID support schemes available to businesses, in particular for those businesses that were most severely impacted by the public health regulations introduced last December.

An extension to the Employment Wage Subsidy Scheme (EWSS) to support those businesses and a number of clarifications in relation to the Covid Restrictions Support Scheme (CRSS) and Tax Debt Warehousing Scheme were agreed by Government at the Cabinet meeting today.

The legislative aspects associated with these changes will be addressed by primary legislation to be introduced in the coming weeks. In the meantime Revenue will update its guidance on each of the schemes shortly.

EWSS

As part of Budget 2022, the government set out the future direction of EWSS including its graduated exit strategy. These arrangements were subsequently enhanced in response to the public health situation, namely the extension of the enhanced rates of subsidy for a further two months (across December 2021 and January 2022) and the reopening of the scheme for certain businesses as announced on 9 and 21 December 2021 respectively.

The government agreed today that businesses availing of EWSS that were directly impacted by the public health Regulations introduced last December, will receive additional support under the scheme for a further month to assist these businesses as they fully reopen and emerge from the restrictions.

Such businesses will continue to receive the enhanced rates of subsidy for the month of February and the graduated step-down in subsidy rates, as previously announced, will be delayed by one month with such firms continuing to receive support under the scheme until 31 May 2022.

From 1 February 2022, most businesses, apart from those that were directly impacted by the public health restrictions of last December, will move to the reduced rate of support of €203 per employee, followed by the flat rate subsidy of €100 per employee for the final two months the scheme of March and April 2022.

It should be noted that the full rate of Employers' PRSI will be reinstated with effect from 1 March 2022 for all businesses, as announced in Budget 2022 and legislated for in the Social Welfare Act 2021.

Tax Debt Warehousing Scheme

In relation to the Tax Debt Warehousing Scheme, and the decision by Government last month, to extend the period where tax liabilities arising can be warehoused to the end of Q1 2022, for all taxpayers eligible for COVID-19 support schemes, it has now been agreed that this date will be extended to 30 April 2022 to facilitate the two monthly VAT return for March/April.

CRSS

A number of clarifications were noted in relation to the CRSS as follows:

  • as provided for under the scheme, an extra week, will be paid to businesses the week after the restrictions are lifted as an additional support to businesses as they reopen fully
  • for newer businesses established during the period 13 October 2020 to 26 July 2021, the turnover from the date of commencement up to 1 August 2021 will be used for the purpose of calculating average weekly turnover
  • certain charities and sporting bodies that operate a hospitality/indoor entertainment business activity from their business premises, who meet the revised qualifying criteria of the scheme, are eligible to apply for the CRSS for the most recent period of restrictions (20 December 2021 to January 2022)

The Minister for Finance, Paschal Donohoe TD said:

"Today is an important day for our society and economy as we seek to ease the public health restrictions and reopen all sectors of our economy. The EWSS has been extremely successful in maintaining employment across the whole of our economy during this pandemic.

"It is now time to adjust our focus towards an exit from the scheme in a structured and orderly way. This is important in everyone's interests - businesses, employees, the wider body of taxpayers – as the scheme cannot continue indefinitely. As such, most businesses will move to the reduced rates of EWSS subsidy from the 1st February 2022 onwards and continue on the exit path as previously announced until the scheme closes on 30 April 2022.

"However, I intend to provide additional support to those businesses that were directly impacted by the most recent public health regulations. Affected businesses will continue to receive the enhanced rates of support for a further month and the exit path from the scheme for such businesses will be delayed by a month.

"CRSS has been an important and successful support payable at times when businesses most needed additional help with their fixed costs, and has provided some €717 million in direct payments in respect of over 25,000 business premises since its introduction and over €13.4 million in payments to businesses directly impacted by the latest public health restrictions in place since 20 December.

"The facility to avail of the Tax Debt Warehousing Scheme has also offered valuable and practical liquidity support to businesses in difficult trading periods during the pandemic. The objective of this scheme is to allow firms some help to recover, thereby helping to guarantee their long-term economic viability and survival. This further extension will allow businesses who have been most impacted some additional time to recover before their tax liabilities have to be paid. Their period of zero interest will continue until 30 April 2023, with interest at the reduced rate of 3% p.a. payable thereafter until the debt is paid down."

01-24-2022

Kenya

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Kenyan High Court Holds Software Payments by Distributor Not Taxable Royalties Without Rights to Commercially Exploit the Software

Kenya's High Court recently issued a judgment regarding the treatment of payments for copyrighted software as taxable royalties. The case involved Seven Seas Technologies Limited, which is a Kenyan company engaged in the distribution of software. In assessing Seven Seas, the Kenya Revenue Authority (KRA) determined that the payments made by the company for the purchase of software constituted taxable royalty payments subject to withholding tax.

The High Court, however, determined that not all software payments may be considered taxable royalty payments. In particular, a software payment can only be considered a taxable royalty payment if the agreement for the payment grants the payer any or all of the rights to commercially exploit the software, including the exclusive right to reproduce the software in any material form and the exclusive right to translate or adapt the software. In the case at hand, Seven Seas was only a vendor of the copyrighted software and did not acquire the right to exploit the copyright in the software. Rather, as a distributor, Seven Seas only purchased and resold the software without being granted tampering or modification rights. As such, the software payments were not royalties subject to withholding tax.

The High Court based its judgment on a judgment of the Indian Supreme Court that was issued in March 2021, which covered several cases involving the treatment of software payments as royalty payments. As previously reported, the Supreme Court determined that payments made by either an Indian resident distributor/reseller or an Indian resident end-user to a non-resident for the use of software do not constitute a royalty and do not fall under the Royalty article in India's tax treaties. The payments must be characterized as plain sales proceeds and, therefore, not subject to withholding tax.

The High Court also relied on the commentary to OECD Model Tax Convention (MTC) for Article 12 (Royalties). This provides that in transactions where a distributor makes payments to acquire and distribute software copies (without the right to reproduce the software), the rights in relation to these acts of distribution should be disregarded in analyzing the character of the transaction for tax purposes. Such transactions would be dealt with as business profits (under MTC Article 7) and not as royalty payments (under MTC Article 12).

01-24-2022

Taiwan

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Taiwan Provides Business Tax Payment Extension for Q4 2021 and January 2022

Taiwan's Ministry of Finance has issued a notice that an extension is being provided for the payment of business tax for Q4 2021 and January 2022.

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The deadline for paying the business tax determined and assessed by the tax authority for the Q4 2021 and January 2022 is extended to 21 February 2022

The Ministry of Finance (MOF) stated that the tax authority shall issue tax payment notices prior to 31 January 2022 and the tax-paying shall be from 1 to 10 February 2022 according to the Article 40 and Paragraph 2 of the Article 42 of the Value-added and Non-value-added Business Tax Act and the Article 45 of the Enforcement Rules of Value-added and Non-value-added Business Tax Act. Owing to the period from 29 January 2022 to 6 February 2022 being Lunar New Year holidays, the MOF is postponing the deadline for the tax payment to 20 February 2022. Since 20 February falls on a Sunday, the deadline will be moved to 21 February 2022 in order to make the payment notices delivered in a proper manner so that business entities can pay taxes before the time limit.

The MOF noted that payment may be made in different ways, such as convenience stores, financial chip card, current (savings) deposit account, ATM transfer, credit card, and mobile.

The MOF reminds taxpayers that if a business entity fails to pay tax before 21 February 2022, it will be regarded as an overdue payment case and a surcharge for delinquent payment shall be levied. The MOF appeals to business entities to pay attention to the above-mentioned extension date and complete their payment before the deadline.

01-24-2022

Ukraine

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Ukraine Clarifies Taxation of Gains from the Sale of Shares in a Resident Company by a Non-Resident

The Ukraine State Fiscal Service recently issued a guidance letter concerning the tax treatment of gains from the alienation of shares in a resident company by a non-resident when sold to another resident company.

The letter provides that under domestic law, such sales are generally subject to 15% withholding tax in Ukraine, with the Ukraine resident buyer required to act as the withholding tax agent. The taxable income is the positive difference between the income received from the sale of the shares and any duly documented expenses incurred by the non-resident in its initial acquisition (i.e., the actual capital gain). If the non-resident does not provide documents confirming its acquisition expenses, the taxable income is the income generated from the sale.

If there is an applicable tax treaty, however, the provisions of the treaty will prevail over domestic law. In the particular case addressed by the letter, the non-resident seller is a Finnish resident and, therefore, the provisions of the 1994 Ukraine-Finland tax treaty apply. As per the provisions of Article 13 (Capital Gains), gains from the alienation of shares are taxable in Ukraine where shares are in a company the assets of which consist mainly of immovable property situated in Ukraine. Where consisting mainly of immovable property situated in Ukraine, the share sale would be taxable according to the domestic withholding tax rules. Otherwise, the sale would not be taxable in Ukraine according to the provisions of the treaty.

01-24-2022
Proposed Changes (3)

European Union

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European Commission Consulting on Initiative for VAT in the Digital Age

On 20 January 2022, the European Commission launched a consultation on its VAT in the Digital Age initiative. This includes a call for evidence for an impact assessment that runs from 20 January to 17 February 2022. The objective of the initiative is to ensure the proper functioning of the single market, to reduce compliance costs for businesses, and to protect the financial and economic interests of the EU and its Member States by combating VAT fraud and ensuring tax equality and neutrality. This will involve:

  • Making compliance with VAT rules easier for EU businesses, particularly those working in the digital economy and those carrying out cross-border trade;
  • Laying down a framework which helps tax administrations to fight VAT fraud, in particular MTIC fraud;
  • Preventing regulatory failure and market fragmentation; and
  • Ensuring fairer treatment of both traditional and platform economies.

The policy options are:

1. Digital reporting requirements, including e-invoicing

The policy options will look at the introduction of partial (limited to cross-border transactions) or fully harmonised (covering domestic and cross-border transactions) digital reporting requirements, including e-invoicing. A further option could be to introduce data storage obligations that will require taxpayers to record transactional data using a pre-determined format and provide information only upon request.

2. VAT treatment of platform economy

The policy responses range from clarifying the existing VAT rules to ensure a more uniform approach to these new business models, to considering whether platforms could play an active role in the collection of VAT.

3. Single VAT registration in the EU

The policy options are to: (i) extend the scope of the one-stop shop (OSS) to include not yet covered business-to-customer supplies; (ii) combine the OSS with simplification measures for intra-EU business-to-business supplies; and (iii) extend/improve the import one-stop shop (e.g., eliminating the EUR 150 threshold and making use of the IOSS mandatory).

Further to the call for evidence, a public consultation has also been launched that runs from 21 January to 15 April 2022. The consultation seeks stakeholders' views on whether the current VAT rules are adapted to the digital age, and on how digital technology can be used both to help Member States fight VAT fraud and to benefit businesses. Views are sought on: (i) VAT reporting obligations and e-invoicing; (ii) the VAT treatment of the platform economy; and (iii) the use of a single EU VAT registration.

01-24-2022

Ghana

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Ghana Government to Resubmit Proposed Levy on Electronic Transactions

On 19 January 2022, Ghana's Minister for Finance, Ken Ofori-Atta, announced that the government will resubmit a proposal for the introduction of a new levy on electronic transactions. As reported earlier, the proposal for the introduction an "Electronic Transaction Levy" or "E-Levy" was included as Part of the 2022 Budget but was rejected in parliament. As originally proposed, the E-Levy would be levied at a rate of 1.75% on electronic transactions covering mobile money payments, bank transfers, merchant payments, and inward remittances. It would be borne by the sender (payer), except inward remittances, which will be borne by the recipient. However, all transactions that add up to GHS 100 or less per day will be exempt from the levy. The new E-Levy was originally proposed to come into effect from 1 February 2022. The effective date of the proposal as resubmitted is uncertain.

01-24-2022

United States

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U.S. Treasury Secretary Remarks on Global Minimum Tax

The U.S. Department of the Treasury has published remarks given by Treasury Secretary Yellen at the 2022 'Virtual Davos Agenda' Hosted by the World Economic Forum. In the remarks, Secretary Yellen primarily addresses the Biden Administration's strategy to sustain economic recovery and to address longstanding structural issues relating to income inequality, racial disparities, and climate change. Secretary Yellen also addressed the agreement for a global minimum tax as follows:

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This past summer, in a remarkable testament to the power of U.S. leadership and multilateralism, 137 countries—representing nearly 95 percent of the world's GDP—have agreed to rewrite the international tax rules to impose a global minimum tax on corporate foreign earnings.

This historic global tax deal will end this race to the bottom by ensuring that profitable corporations pay their fair share, providing governments with resources to invest in their people and economies. At the same time, it will level the playing field so that all multinational companies will face a minimum tax on their foreign earnings, rather than just U.S. companies. This new system will improve productivity by incentivizing businesses to allocate capital to its most productive use, rather than to the use that produces that best tax result. A more efficient allocation of capital via a more level playing field, achieved in a manner that improves fairness for workers, represents a win-win that aligns with the modern supply side approach.

Finally, the agreement will also stabilize the rapidly eroding international tax system by updating its rules to reflect a 21st century economy. The new rules recognize that a business can be meaningfully involved in the economic life of a country without necessarily being physically present there. They will replace a chaotic array of unilateral tax measures that countries enacted in response to growing dissatisfaction with the status quo, but that burdened an increasing scope of U.S. businesses with multiple layers of taxation, discriminated against them, and created trade tensions that threatened economic growth and investment. These new rules can provide much needed tax certainty and clarity to our businesses that will benefit them and their workers.

01-24-2022
Treaty Changes (2)

Luxembourg-Croatia-Greece-Hungary

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Luxembourg Publishes Synthesized Texts of Tax Treaties with Croatia, Greece, and Hungary as Impacted by the BEPS MLI

The Luxembourg tax administration has published the synthesized texts of the tax treaties with Croatia, Greece, and Hungary as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The synthesized texts were prepared on the basis of the reservations and notifications submitted to the Depositary by the respective countries. The authentic legal texts of the treaties and the MLI take precedence and remain the legal texts applicable.

The MLI applies for the 2014 Luxembourg-Croatia tax treaty:

  • with respect of taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2022; and
  • with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 December 2021.

The MLI applies for the 1991 Luxembourg-Greece tax treaty:

  • with respect of taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2022; and
  • with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 January 2022.

The MLI applies for the 2015 Luxembourg-Hungary tax treaty:

  • with respect of taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2022; and
  • with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 January 2022.

Click the following link for the tax treaty page of the Luxembourg tax administration, which includes the MLI synthesized texts.

01-24-2022

United Kingdom-Guernsey-Isle Of Man

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UK HMRC Notes Entry into Force of Tax Collection Assistance Provisions in Tax Treaties with Guernsey and the Isle of Man

UK HMRC has published updates dated 22 December 2021 on assistance in the collection of taxes under the 2018 income and capital tax treaties (agreements) with Guernsey and the Isle of Man. The updates note that the provisions of Article 27 of the treaties, concerning assistance in the collection of taxes, take effect from 1 January 2022 following the Exchange of Letters between the UK and the respective jurisdictions.

01-24-2022
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