The Thai Revenue Department (TRD) issued the revenue ruling No. Gor Kor 0702/1112 on 21 February 2024 (“Ruling”) regarding tax treatment for the new merger scheme under section 1238 (2) of the Civil and Commercial Code. According to the Ruling, the merger would be considered as an entire business transfer and the tax considerations for the EBT should apply.
The Colombian Tax Office (DIAN) issued the Tax Ruling No. 305[008717] of 30 April 2024, interpreting several matters regarding the application of the Significant Economic Presence rules. The following are the most relevant points addressed by the Ruling:
• Cases in which the deduction for payments abroad related to SEP transactions are not capped under article 122 of the Tax Code.
• Identification of SEP taxpayers that have opted for the filing/no WHT mechanism and those who are not subject to the regime.
• Scope of the activities that can be considered taxed under SEP rules.
• Comments on the priority order rules of withholding agents.
The Belgian government adopted a bill which makes significant changes to the Belgian investment deduction regime that will take effect as of FY 2025. The changes will make this tax incentive significantly more attractive given the current economic environment and climate policies. In this webinar, we discussed the changes in the investment deduction regime that are relevant for your companies, with specific attention to the important new “thematic” investment deduction of 30% and the “technology” deduction that can go up to 20.5% of your investment cost.
On 22 March 2024, Treasury proposed regulations identifying exceptions to the 45-day advance notice period that the IRS must provide taxpayers before contacting third parties during audit. The Taxpayer First Act (2019) made several structural changes to the IRS and the Code that—in theory—establish some degree of equilibrium in the audit process and protect taxpayers from (real or perceived) process-related abuses.
One such change was requiring the IRS to provide taxpayers substantive, advance notice before contacting third parties for information during an exam.
On 14 November 2023, the IRS issued the long-awaited proposed implementing regulations (REG-142338-07) under section 4966, added by the Pension Protection Act of 2006 (“Proposed Regulations”). The Proposed Regulations address many definitions related to donor advised funds, donors and donor advisors. The proposed regulations are intended to help taxpayers understand how the imposition of excise taxes on taxable distributions may apply to them.
On 3 May 2024, a new amendment to the Saudi Real Estate Transaction Tax (RETT) Regulations was published in Umm Al Qura pursuant to Ministerial Resolution No. (1-88-1445) dated 02/09/1455 AH.
On 6 May 2024, Decree No. 385/2024 was published in the Official Gazette, extending the scope of the Impuesto PAÍS (“PAIS Tax”) to include the acquisition of foreign currency to distribute profits and dividends, as well as to repatriate nonresidents’ portfolio investments, generated from payments received in Argentina for these concepts from 1 September 2019. In addition, the tax will also apply to the subscription of BOPREAL bonds for the previous purposes.
On 2 May 2024, Decree No. 378/2024 was published in the Official Gazette, extending the deadline for repatriating financial assets of at least 5% of the total value of the assets located abroad until and including 31 May 2024.
As a reminder, the applicable Personal Assets Tax (PAT) rates for assets located abroad will be the same as those applicable to assets located in Argentina if taxpayers repatriate financial assets of at least 5% of the total value of the assets located abroad before 31 March of each year and if certain additional requirements are met.
On 29 April 2024, the Chamber of Deputies approved the bill that the executive branch had sent to Congress as a new draft of the “Bill of Bases and Points of Departure or the Freedom of Argentines,” along with the tax reform package.
The latest edition of our Field Guide to Going Global helps you examine foreign law issues for taking business models, products and technology international. Our guidance should be helpful whether you are working for a start-up company or a large multinational enterprise that is broaching new frontiers.