Two weeks to 19 January 2024
Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK.
UK
Pillar Two
Pillar Two - a Private Capital and Investment Funds perspective
We are pleased to share an exclusive interview with Winnie Tang, PwC's Tax Partner and PwC US Tax Pillar Two specialist in the financial services and private equity industries, shedding light on the significance for Private Capital and principal investors operations.
Committee of Whole House Finance Bill debate
The Finance Bill was debated in Committee of Whole House on Wednesday 10 January. The proceedings can be viewed here (from 14:38). The CIOT, ATT and LITRG’s evidence was cited several times during the debate. Public Bill Committee commenced on 16 January and can be viewed from here. See also Finance Bill: Public Bill committee preview from the CIOT.
Summary of responses to TP/PE/DPT consultation document
As reported previously, the government is developing a package of reforms to three elements of UK international tax legislation: transfer pricing, permanent establishments, and Diverted Profits Tax. The aims of these reforms are to modernise and simplify these rules, in order to improve tax certainty and alignment with treaties. HRMC has now published a summary of responses to its consultation that ran from 19 June to 14 August 2023.
Case law update
- HMRC v Dolphin Drilling Ltd - CA considers meaning of ‘incidental’
The Court of Appeal considers the meaning of ‘incidental’ in the context of Part 8ZA CTA 2010, which is applicable to contractors in the offshore oil industry, in HMRC v Dolphin Drilling Limited, 2024 EWCA Civ 1. Read the decision here. - HMRC correct to refuse late RDEC claim
In Bureau Workspace Ltd v Advocate General for R & C Commrs [2024] BTC 2 the Court of Session considered a taxpayer’s petition for judicial review of HMRC’s decision not to accept their research and development expenditure credit (RDEC) claim. The taxpayer’s agent had submitted documents by the relevant deadline which only partially met HMRC’s published requirements for amending a corporation tax return to include an RDEC claim. HMRC considered the claim incomplete and rejected it. The Court of Session found that HMRC had neither erred in law in refusing the claim, nor acted unreasonably in not accepting a late claim. Read the decision here.
PwC’s 27th CEO survey
- Time for reinvention: CEOs target the acceleration and elevation of critical change
CEOs are determined to drive transformative change in the face of persistent challenges and growth concerns, with a focus on their own catalytic role, investments in necessary skills and technology, and the rise of generative AI (GenAI). Read more in our 27th UK CEO survey. - PwC’s 27th Annual Global CEO Survey - Thriving in an age of continuous reinvention
As existential threats converge, many companies are taking steps to reinvent themselves. Is it enough? And what will it take to succeed? This year’s Global CEO Survey, the 27th we’ve conducted, suggests that the vast majority of companies are already taking some steps towards reinvention. Yet even as CEOs attempt meaningful changes to their companies’ business models, they are even more concerned about their long-term viability. Read more.
EU
Pillar Two
- General Court dismisses action for annulment of the Pillar Two Directive
On 15 December 2023, the General Court of the EU rendered its judgment in Fugro NV vs Council regarding an action for annulment brought by the company Fugro NV against the EU’s Pillar Two Directive. The General Court decided that the company does not have legal standing to challenge the Directive. As a result, the action was rejected, being considered inadmissible, and there was also no need for the Court to adjudicate on the applications to intervene made by the Kingdom of the Netherlands and other parties. Read more in our PwC EUDTG alert.
Advocate General Szpunar: a Member State cannot impose general and abstract obligations on an online service provider operating on its territory but established in another Member State
According to Advocate General Maciej Szpunar, EU law and, more specifically, the Directive on electronic commerce does preclude the imposition of such general and abstract obligations on an online service provider established in another Member State. The opinion was released on 11 January in joint cases Airbnb Ireland (Case C-662/22), Amazon Services Europe (C-667/22), Expedia (C-663/22), Google Ireland (C-664/22), Eg Vacation Rentals Ireland (C-666/22), and Amazon Services Europe (C-665/22).
CFE Tax Advisers Europe
EU Tax Policy News Top 5
The latest round-up of EU Tax Policy news from the Confédération Fiscale Européenne (CFE). The latest edition from 15 January includes: 1) OECD Release Updated Assessment of Impact of Global Minimum Tax; 2) Tax Priorities of the Belgian Presidency of the Council of EU; 3) EU Commission Publishes FAQs on EU Minimum Tax Directive; 4) Next Meeting of the FISC European Parliament Subcommittee; and 5) CFE’s 2023 Tax Policy Report. Visit their latest news page here.
OECD
Pillar Two
- New working paper: The Global Minimum Tax and the taxation of MNE profit
This OECD paper assesses the impact of the Global Minimum Tax (GMT) using new and unique data on MNE worldwide activity building on comprehensive estimates of global low-taxed profit. The paper also extends previous OECD impact assessment work by incorporating a revised methodology that captures the final design of the GMT. Watch the replay of this webinar from 9 January, where the OECD discussed the latest results from the paper outlined above on the impacts of the GMT on the taxation of MNEs.
Public comments received on proposed changes to the Commentary on Article 5 of the OECD Model Tax Convention and its application to extractible natural resources
On 16 November 2023, the OECD invited public comments on the proposed changes to the Commentary on Article 5 of the OECD Model Tax Convention and its application to extractible natural resources. These proposed changes result from the work by Working Party 1 on Tax Conventions and Related Questions - which is the subgroup of the OECD Committee on Fiscal Affairs in charge of the OECD Model Tax Convention - with a view to developing an alternative provision for inclusion in the Commentary on Article 5 of the OECD Model Tax Convention on activities in connection with the exploration and exploitation of extractable natural resources, together with related commentary. The OECD has now published the comments received.
Zambia joins Global Forum as 39th African member
Zambia has joined the international fight against tax evasion as the 171st member – and 39th African member – of the Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum). Zambia is the sixth African country to join the Global Forum in the past eighteen months, following the Republic of the Congo (June 2022), Angola (March 2023), Zimbabwe (April 2023), Sierra Leone (May 2023) and the Democratic Republic of the Congo (December 2023). Read more in this OECD item.
MLI
Latest updates, the text of the BEPS Convention, the explanatory statement, background information, database, and positions of each signatory and parties are available at https://oe.cd/mli including:
Other territories
International
Digital tax byte
The latest edition in our series of brief insights into the workings of the UK and supranational bodies reviewing the taxation of digitalisation of business. In this edition, from 10 January, we cover:
- the European Commission's last minute publication of some Frequently Asked Questions before the commencement of many Member State Pillar Two regimes following the Minimum Tax Directive;
- a failed challenge to the EU's Directive before the Court of Justice and revised estimates of the impact coming from the OECD;
- the European Commission's announcement of the coming into force of new cross-border VAT reporting measures;
- the extension of the deadline in Germany for complying with various requirements of the rules implementing DAC7 on reporting by digital platforms; and
- India has also issued the third set of guidelines on its 1% e-commerce Withholding Tax.
Environmental, Social and Governance (ESG)
- Transforming energy demand
To accelerate the energy transition and deliver on climate ambitions, energy demand transformation needs as much focus as energy supply. Read PwC’s latest report to discover the five actions businesses can take now to transform energy demand.
Australia
Intangibles migration arrangements - finalised PCG
The Australian Taxation Office has released its final Practical Compliance Guideline (PCG 2024/1) which provides a risk assessment framework to enable taxpayers to assess the likelihood of the ATO applying resources to review cross-border related party intangible arrangements. This PCG is the next stage of the ATO’s focus on cross-border intangible asset dealings, and with its compliance approach now finalised, it is likely that we will see a ramp up of reviews.
Updated draft software tax ruling published by ATO
The Australian Taxation Office has published its updated view on the character of payments made under software arrangements in a new draft Taxation Ruling. The draft ruling (TR 2024/D1) will be relevant to software distributors and software owners and includes coverage of arrangements involving digital software distribution, cloud computing arrangements, including software-as-a-service, and packaged software. It also has the potential to cover a broader range of scenarios, such as other technology-based enterprises, and circumstances where software is ‘embedded’ within tangible goods.
Austria
ORF contribution: obligatory contribution for companies from 2024
From 1 January 2024, every household and every business in Austria must pay the ORF (The Austrian Broadcasting Corporation) contribution. For companies, the obligatory contribution applies (for permanent establishments within the meaning of section 4 Municipal Tax Act (KommStG)) per municipality for which municipal tax was paid in the last calendar year. Therefore, if there are multiple permanent establishments in different municipalities in Austria, the ORF contribution must be paid for each individual address. If the address of the company is also a private place of residence, the ORF contribution is payable only once. Read more in this PwC blog.
Barbados
Barbados issues guidance on corporate tax prepayments
The Barbados Government has released guidance on the payment of the territory's new corporate income tax for large multinational enterprises, which applies for income earned from 1 January 2024. The regime features a nine percent rate, with a 5.5 percent rate applying to companies whose gross income is BBD2m (USD1m) or less.
Belgium
See here for latest updates.
Deadline for first DAC7 reporting now imminent
Qualifying platform operators currently have less than 2 weeks to meet the upcoming reporting deadline of 31 January 2024. Any company with a website or app that allows third parties to connect may potentially be in scope of DAC7. The reach of these rules is not limited to the European Union, but extends to numerous platforms and companies established outside the EU as well. Failure to report, or an incomplete or late submission, could lead to fines ranging from € 1,250 to € 25,000. Read more in this PwC news item.
Circular letter relating to the settlement of cross-border tax disputes in the European Union
On 1 December 2023, the Belgian tax authorities issued a circular letter (2023/C/95) relating to the settlement of cross-border tax disputes in the European Union. This circular letter provides clarification to help overcome the difficulties that may arise in the interpretation or application of the law of 9 May 2019 implementing Council Directive (EU) 2017/1852 of 10 October 2017 on tax dispute resolution mechanisms in the European Union. Read more in this PwC news item.
Bermuda
Bermuda enacts a corporate income tax, requiring businesses to begin preparing for compliance
With the assent of the governor on 27 December, the Bermuda Corporate Income Tax Act of 2023 became law. Consistent with the three prior public consultations, a 15% corporate income tax (CIT) will be applicable to Bermuda businesses that are part of multinational enterprise (MNE) groups with annual revenue of €750M or more. The tax is effective beginning in 2025. In addition, the Bermuda Ministry of Finance released a form for making elections pursuant to the CIT, as well as accompanying instructions. A list of frequently asked questions (FAQs) also was released, with an updated version including additional guidance. Read more in this PwC Tax Insights.
Brazil
Brazilian tax authorities implement additional ancillary obligations under new transfer pricing rules
The Brazilian tax authorities recently published Declaratory Acts implementing ancillary transfer pricing (TP) obligations: 1) the Executive Declaratory Act COPES 2/2023 related to the Commodity Transaction registry, mandatory for transactions from 1 January 2024; and 2) the Declaratory Act (COFIS) no. 59/2023 approving layout ‘10’ of the Corporate Income Tax Return (ECF). The new layout was expected to be published since it provides important details with regard to the general TP information that should be reported to the Brazilian tax authorities by 31 July 2024. Read more in this PwC Tax Insights.
China
Interpreting the taxation breakthrough in 2024: Shanghai piloting advance tax rulings to enhance tax certainty
On 29 December 2023, Shanghai Municipal Tax Service of the State Taxation Administration issued the Administrative Measures for Advance Tax Rulings by the Shanghai Municipal Tax Service. As the first set of formal advance ruling procedures released by a provincial or equivalent tax authority in China, it is a landmark in tax administration services. Starting now, enterprise taxpayers in Shanghai can request for advance rulings regarding the application of tax laws and regulations to proposed complex tax matters. The advance tax ruling regime will provide taxpayers, particularly enterprises involved in mergers and acquisitions, and those expanding into emerging markets, with greater tax certainty. Read more in this PwC news alert.
China’s New Company Law - Prepare for launch
The much anticipated new Company Law of the People’s Republic of China was formally approved by the Standing Committee of the National People’s (NPC) on 29 December 2023 and will take effect from 1 July 2024. The new Company Law reflects the most comprehensive revision to Chinese company law since the law was first enacted in 1993, with reforms to numerous aspects of company administration in China, including corporate establishment and governance. Read more in this PwC news alert.
Germany
So-called block acquisitions may meet the terms of Section 8b (4) Sentence 6 Corporation Tax Act
In a recent judgement, the Supreme Tax Court decided that the participation threshold specified in Section 8b (4) Sentence 6 of the German Corporation Tax Act (“CTA”) (10 % of the share capital) can also be attained through an acquisition transaction which is economically uniform from the acquirer's perspective in a situation where several sellers are involved in the transaction. Read more in this PwC blog.
Constitutional Court: Tax privileged transfer of business assets also possible for partnership with identical shareholding
The Federal Constitutional Court held that § Section 6 (5) Income Tax Act (providing for the transfer of business assets at book values) to be incompatible with the German Basic Law insofar as it rules out a transfer at book value between partnerships with identical shareholding. This exclusion from the tax privilege is incompatible with the general guarantee of the right to equality and thus not justified. Read more in this PwC blog.
India
Delhi High Court rules on meaning of permanent establishment and royalty
The Delhi High Court held that the taxpayer has a permanent establishment (PE) in India at the premises of its Indian service recipient. The court dismissed the taxpayer’s contention that profits cannot be attributed if the taxpayer had incurred losses at a global level, which was held in the coordinate bench decision in the case of Nokia Solutions Network. Therefore, the court, expressing its reservation against the said coordinate bench decision, has referred the instant case for consideration by a larger bench. As regards the consideration for fee received in terms of the service agreement, alleged as ‘royalty’ by the Revenue—the court noted that the taxpayer provided know-how in furtherance of the oversight and strategic planning services. Thus, the court concluded that such fee is business income and not royalty. Read more in this PwC alert.
Liaison Office constitutes a PE if its activities go beyond merely acting as a communication channel between HO and clients in India
The Delhi bench of the Income-tax Appellate Tribunal recently concluded that activities of the Liaison Office (LO) of a German company in India constitutes a permanent establishment (PE) as per Article 5 of the India-Germany double tax treaty (DTT) where the activities involved pertained to determining the book titles to be published, procuring orders, determining selling price and profits, etc. and thus, were not preparatory or auxiliary in nature. Read more in this PwC alert.
Ireland
Irish Revenue adds to interest limitation rule guidance
The Irish Revenue has updated its Tax and Duty Manual 35D-01-01 to include a new section (section 15) dealing with the interaction of the Interest Limitation Rule and foreign currencies.
Irish Revenue updates anti-hybrid tax law guidance
Tax and Duty Manual 35C-00-01 has been updated to reflect the introduction of a new definition of "entity" for the purposes of Ireland’s anti-hybrid rules, which has been broadened to provide that the rules apply to any legal arrangement, rather than only to legal arrangements involving the ownership of taxable assets.
Italy
New documentation requirements to counteract hybrid mismatches
Article 61 of the International Tax Decree introduces the possibility for taxpayers (part of domestic and non-Italian groups) to prepare a set of documents to obtain the so-called penalty protection in case of challenges concerning hybrid mismatches, similar to what is already provided for in the area of transfer pricing. Read more in this PwC blog.
Sale of Italian REIF units escapes from the Italian “land rich” rule
Beginning in 2023, the Italian income tax system has included “land rich” provisions applicable to the disposal of shareholdings in Italian resident and non-Italian resident “companies and entities” which are (either directly or indirectly) “rich” in Italian real estate. On 22 December 2023, the Italian Tax Authorities clarified (via Resolution no. 76) that Italian REIF units do not fall under the definition of “companies and entities” for this purpose. Consequently, the (direct) sale of Italian REIF units (as well as RE SICAF shares) escapes these “land rich” provisions and capital gains realised by non-Italian “institutional” or not-“substantial” unitholders therefore continue to benefit from the domestic tax exemption if they are tax resident in white-listed jurisdictions. Read more in this PwC alert which provides our view on why there may be a possible exception to this general rule.
Liechtenstein
Liechtenstein enacts Pillar Two rules
Following its approval by the Liechtenstein parliament on 10 November 2023, the Liechtenstein government enacted the GloBE Law (global minimum tax) on 22 December 2023 to enter into force as of 1 January 2024. Consequently, Liechtenstein groups and companies within the threshold of global minimum tax will be subject to the Qualified Domestic Minimum Tax (‘QDMTT’) and Income Inclusion Rule (‘IIR’) of 15 % for tax years starting on or after 1 January 2024. The effective date of the Undertaxed Profits Rule (UTPR) is to be defined separately through a second ordinance and can only enter into force on 1 January 2025 at the earliest. As such, it remains open when UTPR may be introduced. Read more in this PwC blog.
Middle East
Bahrain set to introduce corporate income tax
Recent parliamentary discussions were held with representatives from the National Bureau for Revenue and His Excellency the Minister of Finance and National Economy, Shaikh Salman bin Khalifa Al Khalifa surrounding the implementation of a corporate income tax in Bahrain. No official date has been announced in relation to the implementation of the tax. Read more in this PwC alert.
Oman ratifies the Double Tax Treaty with Russia and Tax Authority’s Announcement on Automatic Exchange of Information “AEOI”
On 8 June 2023, Oman and Russia (“the contracting states”) signed a Double Tax Treaty (“DTT”). Royal Decree (RD 89/2023) was issued on 27 December 2023 by His Majesty the Sultan of Oman, ratifying the DTT which was published in the Official Gazette on 31 December 2023. Given that Oman and Russia have both ratified and formally notified each other of the completion of the ratification procedures, the DTT will come into effect on 1 January 2024.
In addition, the Oman Tax Authority (OTA) has released an announcement regarding the fact that the Automatic Exchange of Information “AEOI” portal is unavailable whilst a new system is being built. The deadline for CbCR notifications for affected entities has been extended until the AEOI portal becomes accessible. No date has been notified as to when the portal will be ready.
Read more in this PwC alert.
Romania
The assets taken into account for the determination indicators I and A when calculating the minimum turnover tax: OMF no.10/2024
Order of the Minister of Finance (OMF) no. 10/2024 introduced the eligible assets to be taken into account when determining indicators I and A in the formula to establish: 1) the minimum turnover tax owed by companies with a turnover of over EUR 50 million, according to art. 181 para. (3) Fiscal Code; and 2) the specific tax on turnover due in addition to the profit tax by companies that carry out activities in the oil and natural gas sectors, according to art. 183 para. (2) the Fiscal Code. Read more in this PwC alert.
Russia
Oman ratifies double tax treaty with Russia
On 8 June 2023, Oman and Russia (“the contracting states”) signed a double tax treaty. Royal Decree (RD 89/2023) was issued on 27 December 2023 by His Majesty the Sultan of Oman, ratifying the DTT which was published in the Official Gazette on 31 December 2023. Given that Oman and Russia have both ratified and formally notified each other of the completion of the ratification procedures, the treaty came into effect on 1 January 2024. Read more in this PwC alert.
Singapore
Update to the taxation of gains on disposal of foreign assets
Changes to Singapore’s tax regime for foreign-sourced income, first proposed in June 2023, came into effect on 1 January 2024. A new section 10L of the Income Tax Act 1947 imposes tax on gains from the disposal of foreign assets taking place on or after 1 January 2024 when they are received in Singapore by an entity of a relevant group (unless certain exclusions apply). On 8 December 2023, the Inland Revenue Authority of Singapore (IRAS) published its e-Tax Guide “Income Tax: Tax Treatment of Gains or Losses from the Sale of Foreign Assets” to further clarify the scope of this new taxing provision, the economic substance requirements for exclusion from this tax, and certain administrative requirements including an avenue for businesses to obtain an advance ruling on the adequacy of their economic substance. Read more in this PwC alert.
Singapore updates common reporting standard guidance
The Inland Revenue Authority of Singapore recently updated its guidance on the automatic exchange of financial account information under the Common Reporting Standard.
Switzerland
For the latest updates on current topics, see this PwC Switzerland Insights page.
US
Tax committee chairs announce business and family tax relief agreement
House Ways and Means Committee Chairman Jason Smith and Senate Finance Committee Chairman Ron Wyden have announced a bipartisan, bicameral tax framework agreement on business and individual tax relief. The proposed “Tax Relief for American Families and Workers Act of 2024” restores Section 174 expensing for US-based R&D investments, the EBITDA-based business interest limitation under Section 163(j), and 100% 'bonus' depreciation under Section 168(k) through the end of 2025 on a retroactive, seamless basis. Notably, Section 174 expensing is not restored for foreign R&D expenses, which will remain subject to 15-year amortization. Read more in this PwC Tax Insights and view our Policy on Demand episode entitled ‘Expansive tax bill includes nuances, offsets’.
Pillar Two Guide for US Multinational Enterprises: What private companies and family offices need to know
The Pillar Two tax rules for multinational companies went live 1 January 2024. While some have planned for this eventuality, some — including many private businesses — may not have considered international investments and cross-border revenue levels. Read the private company highlights here.
Tax Court rules foreign partnership was engaged in US trade or business
In November, the Tax Court released its long-awaited decision in YA Global v. Commissioner, 161 TC No. 11, concluding, among other things, that a foreign partnership (YA Global Investments, LP, the “Fund”) was engaged in a US trade or business that generated US-sourced income effectively connected to that US trade or business. Read more in this PwC Tax Insights
Proposed regulations would update the conclusive presumption rules for bad debts of eligible financial entities
Treasury and the IRS recently issued proposed regulations under Section 166 that would provide guidance regarding whether a debt instrument is conclusively presumed to be worthless for Federal income tax purposes for eligible entities, primarily banks and insurance companies. Under the proposed rules, regulated financial companies and members of regulated financial groups would have the option to use a new method of accounting for Federal income tax purposes that generally follows book charge-offs for recognizing tax losses from partially worthless or wholly worthless debts. Read more in this PwC Tax Insights.
Treasury finalises de minimis error safe harbour rules for information returns and payee statements
Treasury and the IRS recently issued final regulations implementing statutory safe harbour rules that protect filers from penalties for failure to file correct information returns or furnish correct payee statements. The safe harbour rules treat information returns and payee statements with erroneous dollar amounts as correct returns or statements for certain penalty purposes if the errors are de minimis in dollar amount. Read more in this PwC Tax Insights.
IRS releases guidance related to Section 961 and certain inbound nonrecognition transactions
Treasury and the IRS recently released Notice 2024-16 which applies to transactions where a lower-tier CFC becomes a first-tier CFC and addresses the Section 961 basis consequences to its US shareholders. Read more in this PwC Tax Insights.
IRS issues long-awaited guidance on implicit support recognition for intercompany loan transactions
On 29 December 2023, the IRS Office of Chief Counsel issued long-awaited guidance on the effects of group membership on financial transactions under Section 482. The guidance was issued in the form of a generic legal advice memorandum (GLAM). The GLAM examines the application of the 482 regulations applicable to intercompany loans and other areas of the 482 regulations, including realistic alternatives and passive association, in the context of intercompany lending. Applying these principles, the GLAM concludes that the IRS may consider group membership in determining the arm’s length rate of interest for intercompany loans based on implicit financial support expected from another group member. Read more in this PwC Tax Insights.
PLR provides REIT guidance on storage terminal facilities
In Private Letter Ruling 202346008 (PLR), the IRS issued several rulings to a corporation (taxpayer) that intended to elect to be taxed as a real estate investment trust (REIT). The taxpayer owned bulk liquid storage terminal facilities (storage terminal facilities) constructed on land it either owned or leased. The PLR provided several favourable rulings analysing whether certain income streams and other payments received by the taxpayer should be included or excluded for purposes of the REIT income tests. Read more in this PwC Tax Insights.
Policy on Demand series
- Expansive tax bill includes nuances, offsets
Congressional tax writers announced an expansive bipartisan tax bill which includes nuances and offsets. The path to passage is expected to begin this week. Watch this episode from 16 January. - 2024 Policy Outlook
PwC’s 2024 Tax Policy Outlook is out and in this episode from 10 January, the policy team touches on different aspects of the outlook. More questions are answered on our website and a live discussion will follow on this webcast taking place on 17 January. - Week in Review
- 19 January – Rohit Kumar talks about the Smith-Wyden tax agreement and the big question about the bill: how and when could it pass? As for the week ahead, Rohit is focusing on the public response to the bill and next week's New Hampshire primary. Watch now.
- 12 January – Congressional tax writers have agreed to a tax package that includes Section 174 research expenditures, interest deduction limitations, bonus depreciation, and the child tax credit. Details are yet to come, but it’s crunch time for companies to make their voices heard to lawmakers. Watch now.
Tax Readiness webcast series
- New year, new updates on US international and global tax
Join our panel of PwC international tax specialists on Tuesday 23 January at 9pm, as they share their insights on recent and upcoming guidance on international tax issues facing multinational corporations. The panel will discuss guidance around the OECD’s Pillar Two initiative, the foreign tax credit (FTC), the corporate alternative minimum tax (CAMT), and previously taxed earnings and profits (PTEP). Register here. - Tax Readiness: 2024 Tax Policy Outlook
Watch this webcast replay from17 January, where our panel review our 2024 Tax Policy Outlook, outline the upcoming tax policy decisions to be made and delve into the significant hurdles faced by business leaders. This includes strategies on effectively engaging with policymakers and the public to garner support for tax policies that foster future economic growth, business investments, and job creation. - Tax Readiness: Future of Tax – Topics shaping the tax agenda
The opportunity for Tax to enable and influence business strategy has never been greater – from business model reinvention, to climate investments, and Pillar Two. In this webcast replay from 12 December, we share the new capabilities that leading tax functions are prioritising to support their organisation's broader commercial strategy.
Further information
You can sign up for Tax Alerts issued by the US to be emailed to you. Subscribe using the link on this page. A back catalogue of previous webcasts and other resources are available on our US tax reform hub here.
Zambia
Zambia joins Global Forum as 39th African member
Zambia has joined the international fight against tax evasion as the 171st member – and 39th African member – of the Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum). Zambia is the sixth African country to join the Global Forum in the past eighteen months, following the Republic of the Congo (June 2022), Angola (March 2023), Zimbabwe (April 2023), Sierra Leone (May 2023) and the Democratic Republic of the Congo (December 2023). Read more in this OECD item.