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In AML & Financial Services Regulatory

Venezuela: Decree exonerates foreign currency debits that generate certain transactions with securities from paying the Large Financial Transactions Tax

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The National Executive Power issued Decree No. 4924 on 21 February 2024, which exonerates the following from paying the Large Financial Transactions Tax (LFTT): (i) debits that generate the purchase, sale or transfer of securities issued or guaranteed by the Republic or the Central Bank of Venezuela, (ii) debits or withdrawals related to the payment of their capital or interest, and (iii) securities traded in different stock exchanges or the agricultural stock exchange, made in a currency other than the legal tender.

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In Tax

United Kingdom: Update on changes to res non-dom regime and possible further reform

by , , , , and 7 Mins Read

On 6 March 2024, the current government (led by the Conservative Party) announced a number of significant changes to the way in which UK tax resident non-UK domiciled (RND) individuals will be taxed in future. These changes are expected to take effect from 6 April 2025. In this alert we provide a recap of the reforms announced by the current Conservative government, and an overview of the further changes that the Labour Party has said it will introduce if elected.

In Tax

Bahrain: The National Bureau of Revenue (NBR) extends record retention period to 10 years

by , and 2 Mins Read

On 28 February 2024, the NBR notified taxpayers via email and an announcement on its webpage that the record retention requirement for Value-Added Tax has been extended from five to ten years. The initial five-year record retention period for the 1 January 2018 – 31 March 2018 tax period (Q1 2018) would have lapsed as of 31 March 2024, but now has been extended to 31 March 2029.

In Brazil

Brazil: Brazillian IRS publishes Normative Instruction regulating the taxation of investments abroad

by , and 4 Mins Read

On 13 March 2024, the Brazilian IRS published Normative Instruction 2.180/24 (“IN 2.180/24”), which provides for the taxation of income earned by individuals resident in Brazil from non-interest-bearing deposits abroad, foreign currency held in kind, financial investments, controlled entities and trusts abroad, as well as the option to update the value of assets and rights abroad.
The long-awaited IN 2.180/24 regulates Law 14,754/23, which was passed on 12 December 2023 and brought important clarifications regarding the taxation by Income Tax of individuals (IRPF) with assets abroad.

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In Tax

Belgium: Anti-dumping as a business strategy (Webinar)

by , and 2 Mins Read

Anti-dumping and anti-subsidy rules are a powerful tools that Belgian/EU goods manufacturers can employ to support their business. Anti-dumping and anti-subsidy measures take the form of additional import duties that are due on competing imported goods. These duties, which are in force for an average of 12 years and are at an average level of 30%, reduce the import volume of imported goods by an average of 85%. They thus significantly reshape markets for prolonged periods.

In Tax

United States: Greenbook offers few surprises for a second Biden term

by , and 3 Mins Read

On 9 March 2024, the Biden Administration released its proposed budget for fiscal year 2025, and the Treasury Department released its General Explanations of the Administration’s Fiscal Year 2025 Budget Proposals, commonly known as the “Greenbook.” Many of the proposals in this year’s Greenbook appeared in earlier years, but a few proposals are new or modified. Due to the divided Congress and competing political priorities during a general election year, there is little chance that any of the Greenbook proposals will be passed into law in 2024. However, the Greenbook illustrates the consistency of the President’s tax policy objectives during his first term and maps out priorities for a possible second term.

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In Tax

United States: Navigating the Implications of the CHIPs Act

by and 11 Mins Read

On 5 March 2024, Treasury and the IRS published Treas. Reg. § 1.48D-6 (“Final Regulations”), which implements the section 48D(d) election allowing eligible taxpayers to treat the amount of the advanced manufacturing investment credit (“CHIPs Credit”) established under the Creating Helpful Incentives to Produce Semiconductors Act of 2022 as a payment against Federal income tax liabilities, i.e., a “direct pay election” For eligible taxpayers seeking to treat the CHIPs Credit allowed in any tax year as a payment against Federal income tax liabilities in lieu of claiming the credit, the Final Regulations generally retain the structure and framework for administering the election laid out in proposed and temporary regulations, with welcome modifications to clarify key issues relating to the limitations for making the elective payments, the ‘denial of double benefits’ rule, and the election’s pre-filing requirements.

In Tax

Belgium: Ahead of Tax – Corporate income tax and Transfer pricing (Webinar)

by and 2 Mins Read

In this webinar session, we discussed the latest audit trends and focus areas of the cell for large enterprises, the Transfer pricing cell and the Special tax investigation office (e.g., tax treatment of reorganizations, EBITDA 30%-rule, group contribution, transfer pricing implications of financial transactions, hard-to-value intangibles, etc). We analyzed the triggers leading to a tax audit and best practices on how to best handle a tax audit. Finally, we looked ahead and discussed the impact of new regimes, such as CFC, Pillar two, the public CbCR, and multilateral tax audits.

In Tax

Belgium: Ahead of Tax – VAT, customs and trade (Webinar)

by , and 2 Mins Read

In this session, we covered the expected implications for VAT audits going forward and gave an overview of the expected areas of focus. VAT and customs often go hand in hand, hence we also covered customs audits and investigations which are very complex and are often difficult to handle for groups due to limited compliance resources in this field. We also took this opportunity to touch upon the difficulties faced by companies regarding the different sanction packages adopted by the EU Commission and uncovered what a typical trade investigation looks like and what the focus areas are. Finally, we provided recommendations on how to best avoid an adverse outcome by implementing quality control and monitoring procedures.

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