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As of 1 January 2025, the Netherlands will introduce new rules with respect to the qualification of legal forms as either transparent (look-through/disregarded entity) or non-transparent (separate taxpayer/regarded entity) from a Dutch tax perspective.
An important change is that Dutch limited partnerships and comparable foreign partnerships will be considered transparent from a Dutch tax perspective, even if the participations are freely transferable.

At the end of last year, the Belgian Parliament adopted a new Program law, which includes new rules on the controlled foreign company regime in Belgium applicable as of tax assessment year 2024.
In this webinar, we briefly explain the new rules, how they will impact you, and what the remaining uncertainties are.

On 8 December 2023, Treasury and the IRS released Notice 2024-16 announcing their intent to issue proposed regulations addressing the treatment of basis under section 961(c) in certain inbound nonrecognition transactions in which a domestic corporation acquires the stock a controlled foreign corporation (CFC) from another CFC. These proposed regulations are in addition to the highly anticipated proposed previously taxed earnings and profits (PTEP) regulations expected this year. According to the Notice, the proposed regulations will provide that, in the case of certain “covered inbound transactions,” the domestic acquiring corporation’s adjusted basis in the acquired CFC stock (as determined under section 334(b) or 362(b)) will be determined as if the transferor CFC’s section 961(c) basis were adjusted basis.

On 1 April 2024 new provisions contained in the Financial Code for the State of Mexico will become effective, with regard to the following taxes:

  1. Ecological Tax on Waste Disposal, Confinement and Storage (“The Waste Tax”);
  2. Tax on Pollutant Emissions to Water (“Water Tax”).

There are also new rates applicable to the Tax on Pollutant Air Emissions (“Air Emissions Tax”), in force since 2022.

Investigations are an essential tool for ensuring a company’s ethical standards are being followed by employees, business partners, and any others with whom the company interacts. However, investigations are also an essential tool for demonstrating and maintaining strong corporate governance – an integral part of a company’s ESG commitments and strategy. It is also a good time to set yourself some goals and resolutions. To help you on your way, we are pleased to share our top 5 Lunar New Year Resolutions for handling Internal or Government Investigations

The Canary Islands Government has decided to reduce the tax rate applicable to different goods and services including medical devices, veterinary medicines and veterinary services. These changes are expected to facilitate patients’ access to these products and services by reducing their costs.

In the recent case of Soroban Capital Partners LP v. Commissioner, 161 T.C. No. 12 (2023), the Tax Court held that the limited partner exception under section 1402(a)(13) does not apply to limited partners who the Court concluded were not limited partners “as such”; thus certain “limited partners” of a partnership may be subject to Self-Employed Contributions Act tax. The Tax Court in Soroban held that determining a “limited partner” for section 1402(a)(13) purposes requires a factual inquiry into the functions and roles carried out by such limited partner. If the factual inquiry shows that a limited partner is heavily involved in the partnership’s business and/or performed services for the partnership, such limited partner’s distributive share may be subject to Self-Employed Contributions Act tax.

On 27 December 2023, the BIR published RR No. 16-2023 to amend RR No. 2-1998 and impose withholding tax on the gross remittances by e-marketplace operators and digital financial services providers to sellers/merchants. On 11 January 2024, the BIR issued RMC 8-2024 to provide guidance on the timeline and procedures to implement RR No. 16-2023. According to RR No. 16-2023, e-marketplace operators and digital financial services providers are allowed a transitory period of 90 days from the issuance of RMC 8-2024 to comply with the provisions of RR No. 16-2023.