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In Tax

Japan: Recent Developments in Japanese Tax Law

by 1 Min Read

Japan’s 2023 tax reform package announced in December 2022 and submitted to the Diet in February 2023 includes various measures aimed at strengthening the Japanese start-up ecosystem and reorganizing the research and development taxation system. In an article published in Tax Notes International, Luke Tanner provides an overview of the recent tax developments in Japan, including the tax reform package and other legislation, the OECD’s two-pillar proposal, changes to consumption tax, and the transfer pricing regime.

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In Tax

Luxembourg: New Bill simplifying and modernizing procedural aspects in tax matters introduced

by , , , and 7 Mins Read

On 28 March 2023, the government presented Bill of Law 8186 (“Bill”), which provides a set of amendments to the General Tax Law (Abgabenordnung, AO) dated 22 May 1931 and introduces new procedural aspects applicable to taxpayers. The Bill also introduces new bilateral and multilateral advance pricing agreement procedures, together with the possibility to issue, withdraw or amend a tax assessment further to a mutual agreement procedure or an arbitration decision. Lastly, the Bill proposes a transfer pricing documentation requirement for transactions between associated enterprises, while further details regarding the scope, exact content and magnitude will be unveiled soon in a coming grand ducal decree.

In Tax

Belgium: Ahead of Tax – Unshelling the adapted ATAD 3 Proposal (Webinar)

by , and 2 Mins Read

At the beginning of this year, the European Parliament proposed certain amendments with respect to the EU initiative to target so-called “shell” entities (i.e., entities which are considered to be devoid of economic substance). The European Commission published already in 2021 a proposal for an EU Directive intended to neutralize the misuse of such shell entities in the EU for tax purposes (also known as “ATAD 3” or “Unshell Directive”). The tax world raised, however, a lot of concerns regarding this initiative and such in particular in light of the many uncertainties on how to interpret the proposed text.

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In Trade and Foreign Investment

Thailand: BOI – New announcements on promoted activities & privileges

by , , , and 3 Mins Read

The Thailand Board of Investment (BOI) has issued new announcements to respond to new businesses and future investment trends and to attract investors to invest in Thailand. The BOI aims to boost innovation, competitiveness, and inclusivity as well as sustainable development of Thailand’s economy in accordance with the current National Economic and Social Development Plan and the country’s development policies.

In Tax

Germany: German Federal Ministry of Finance publishes Pillar 2 draft implementation law

by , and 5 Mins Read

Over the last few months there have already been a number of legislative developments in connection with the global minimum tax under Pillar 2 all around the world. It is fair to say that Pillar 2 is increasingly gaining momentum and a critical mass of implementing jurisdictions could be reached in the foreseeable future. Germany is now the next country taking actions to implement Pillar 2 into domestic law. On 21 February 2023, the German Federal Ministry of Finance has published a draft law including explanatory comments.

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In Peru

Peru: Doing Business in Peru 2023

by , and 1 Min Read

Estudio Echecopar, a member firm of Baker & McKenzie International, has updated the Doing Business in Peru 2023 guide to provide investors with useful information on the legal and regulatory framework they need to know to do business in the country. The guide focuses on the relevant aspects of legislation, the legal system, safeguards and other important nuances of local regulations to help investors conduct and maintain successful activities in Peru.

In Tax

United States: IRS eases US TIN compliance concerns for FFIs under FATCA

by , and 4 Mins Read

Treasury and the IRS issued temporary relief procedures in Notice 2023-11 for a foreign financial institutions (FFI) that is subject to a Model 1 intergovernmental agreement (IGA) jurisdiction.
Model 1 FFIs that follow the procedures set forth in the Notice will not be in significant non-compliance with their obligations under an applicable Model 1 IGA solely because of a failure to report a required US taxpayer identification number (TIN) in relation to “preexisting accounts”.

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