Two weeks to 2 June 2023
Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK.
UK
Pillar Two
- Webcast: A practical guide to surviving Pillar Two
In this client webcast taking place Thursday 22 June at 10am, PwC’s Matt Ryan, Rob Gooding and Jos Bhasker will give an update on Pillar Two implementation globally, and propose some practical steps organisations can take to overcome some of the key challenges they are facing. We will also walk through the technology solutions being developed for compliance and reporting. The registration link is available here. - The Pillar Two challenge for business leaders and actions to initiate now
Global compliance obligations, including tax provisions and local filings, are already exceptionally complicated and demanding for tax departments and administrators. Pillar Two’s complexity, novelty and associated uncertainty compound these challenges. Put simply, this overhaul of the international tax framework is a massive undertaking for tax, accounting and finance departments that are already spread thin. Read more in this article by Doug McHoney, PwC’s International Tax Services Global Leader. - Updated Pillar Two Country Tracker
We’ve updated our Pillar 2 Country Tracker to include information about safe harbours, the ability to expand all content, and added updated country profiles. - ICAEW comments on draft pillar two model rules
The ICAEW has welcomed the opportunity to comment on the FRED 83 Draft amendments to FRS 102 and FRS 101: International tax reform - Pillar Two model rules published by the Financial Reporting Council in April 2023. You can read the ICAEW’s comments here.
Case law update
- Withholding tax on interest - FTT decision in Hargreaves Property Holdings Limited upheld
The Upper Tribunal (UT) has dismissed the taxpayer’s appeal in Hargreaves Property Holdings Limited v HMRC [2023] BTC 517, upholding the earlier decision of the First-tier Tribunal (FTT) regarding the obligation to withhold tax (WHT) on interest. The UT decision applies the well established precedent set by the Court of Appeal in Ardmore, reaffirming that when considering whether interest is yearly and has a UK source, the emphasis will be placed on the underlying commercial reality of the arrangements. It was also held that interposing a company with no commercial purpose other than to sidestep the WHT provisions was not effective in shifting beneficial entitlement to the interest to a UK resident company, and therefore did not result in the interest being an excepted payment which falls outside the WHT obligation. Read the full decision here.
COST Forum on US State and Local Taxes for European Companies - London 20 June 2023
PwC is one of the sponsors of the COST Forum on US State and Local Taxes for European Companies, a one day conference on US State and Local Taxes for European companies that will be held in our Embankment Place office in London on 20 June 2023. Leading practitioners with dedicated knowledge in this area, including our very own Rob Ozmun and Dorothy Lo, will help attendees understand the tax requirements and risks of doing business or expanding into the vastly lucrative US market. Differences between the US and European tax systems will be covered and attendees will learn about threshold issues such as nexus and jurisdiction. You can find the agenda and registration link here.
Finance (No 2) Bill 2023
The Finance Bill has now completed the Public Bill Committee stage. Explanatory Notes for government amendments at this stage can be seen here. The Bill is now due to have its report stage and third reading, on a date yet to be announced. It will be substantively enacted for UK GAAP and IFRS purposes once those stages have been completed.
Treaty updates
- Double Taxation Treaty Passport Scheme - new version of DTTP1 form published
HMRC added a new version of the DTTP1 form to renew a Double Taxation Treaty passport to its website here on 2 June 2023.
MDR cross-border arrangements guidance update
HMRC have updated their guidance to include information on business rules for submissions with error messages.
FRS 102 amendments: FRED 82 consultation now closed, next steps
The consultation period for FRED 82 has now closed and we await the final conclusions of the FRC. The FRC are hopeful the final amendments will be available by the end of this year. To give entities time to prepare, the FRC has committed to give entities at least 12 months from publishing the amendments to the effective date, currently expected to be 1 January 2025. Read more.
Talking Tax, May 2023
Read the latest edition here which includes: 1) Reframing tax: Moving from spreadsheets to automation; 2) The Pillar Two challenge for business leaders and actions to initiate now; 3) IR35 off-payroll working rules - a resolution to the ‘offset issue’? 4) Connected tax compliance: Simplifying and future proofing tax operations; and 5) Full expensing - a new and valuable capital allowance.
HMRC Manual updates
The following changes have recently been made by HMRC following review:
- Business Income Manual - updated 23 May
HMRC has updated section BIM37790 - Wholly and exclusively: duality of, or non-trade, purpose: loans/advances to others: to allow subsidiaries to meet their obligations to reflect wording in the Scott Bader decision. - Digital Services Tax Manual - updated 24 May
HMRC has added a discontinued operations section to DST22000 - Definition of Revenues for DST. - Corporate Finance Manual - updated 31 May
- CFM96250: Interest restriction: related parties: 25% investment - attribution of rights and interests: persons acting together
- CFM98210: Interest restriction: carry forward rules: introduction
- CFM98230 - Interest restriction: carry forward rules: carry forward of interest disallowance
- CFM98255 - Interest restriction: carry forward rules: excess debt cap and new 'topco'
- CFM98450 - Interest restriction: administration: reporting requirements: Statement of Calculations: TIOPA10/SCH7A/PARA21
- CFM98470 - Interest restriction: administration: reporting requirements: appointment of a reporting company by group: TIOPA10/SCH7A/PARAS1-3
Approved offshore reporting funds
HMRC has updated the list of approved offshore reporting funds to include the latest funds that have entered the Reporting Fund Regime. The list has been updated to include the funds that have entered as at 1 June 2023. View the updated list.
EU
European Finance Ministers adopt new reporting and exchange of information rules centred around crypto-assets
As reported in our previous edition, European Finance Ministers met on 16 May as part of the monthly European Council ECOFIN meetings, and agreed to proposed changes to the Directive on Administrative Cooperation in the area of taxation. The changes to the Directive (DAC8) shall, in principle and with minor exceptions, be implemented in EU Member States’ legislation by 31 December 2025 and apply from 1 January 2026. While a reporting regime for crypto assets is a core component, the Directive also includes measures strengthening and broadening DACs 1-7, although proposals to provide for minimum penalties have not been agreed. Once the European Parliament presents its opinion on the proposal following final legal checks, the Directive can be formally adopted. This PwC Tax Policy Alert has now been prepared.
General Court to dismiss action by Meta Platforms against Commission’s request for disclosure of documents
The action brought by Meta Platforms Ireland (Facebook group) against a request from the EU-Commission for release of documents identified by means of search terms or by way of specific keywords was dismissed by the European General Court. Read the judgment here and related PwC tax blog article.
G7 Annual Summit
The leaders of the Group of Seven (G7) met in Hiroshima, Japan, on 19-21 May 2023. They were joined by the leaders of Australia, Brazil, the Comoros, the Cook Islands, India, Indonesia, Republic of Korea, Vietnam and Ukraine. During the meeting, the G7 leaders emphasised their strong political commitment towards the swift global implementation of the OECD/G20 Inclusive Framework Two-Pillar Solution. Read more in this G7 Hiroshima Leaders’ Communiqué.
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 22 May includes: 1) G7 Welcome Progress on Two-Pillar International Tax Process; 2) AG Kokott: State Aid Law Should Apply to Outlier Tax Cases Only; 3) Save the Date: CFE, ICAEW & PwC Event: “A Gender Equal Tax System in Europe: Reflections for a New Agenda” – 4 July 2023; 4) EU Ministers Approve DAC8 (Crypto-Assets Reporting); and 5) European Commission BEFIT Summary Report. Visit their latest news page here.
OECD
Pillar Two
See our UK section above for updates on the UK implementation of Pillar Two and our international section below for updates regarding the steps other territories are taking in relation to Pillar Two.
- Updated Pillar Two Country Tracker
We’ve updated our Pillar 2 Country Tracker to include information about safe harbours, the ability to expand all content, and added updated country profiles. We’re also working to develop export options, so we’ll keep you updated as the tool develops. - Accounting
- IASB consults on proposed amendments to IFRS for SMEs Accounting Standard related to international tax reform
On 1 June, the International Accounting Standards Board (IASB) proposed amendments to the IFRS for SMEs Accounting Standard to help small and medium-sized entities (SMEs) respond to international tax reform. It is the first time that the IASB has proposed urgent amendments to the Standard outside its periodic review. Read more in this IFRS news item. - IASB confirms BEPS 2.0 Accounting Standard Change
The International Accounting Standards Board (IASB) has issued amendments to IAS 12 Income Taxes. The amendments give companies temporary relief from accounting for deferred taxes arising from the OECD's international tax reform. Read more in this IFRS news item.
- IASB consults on proposed amendments to IFRS for SMEs Accounting Standard related to international tax reform
Latest on OECD project; What's next after debt limit deal?
In this episode from 30 May, Will Morris shares the latest on Pillars One and Two, including the staggered implementation of Pillar Two and recent US developments.
MLI
- Vietnam ratifies the BEPS MLI
Vietnam has deposited its instrument of ratification for the BEPS multilateral instrument. The BEPS MLI will enter into force for Vietnam from 1 September 2023. - Spain confirms the completion of its internal procedures for the entry into effect of the provisions of the MLI under Article 35(7)
This document contains all of the notifications made by the Kingdom of Spain confirming the completion of its internal procedures for the Covered Tax Agreements identified in this document pursuant to Article 35(7)(b) of the Convention.
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.
Global Forum Secretariat assists members to ensure the effective implementation of automatic exchange of financial account information
The Global Forum Secretariat has developed a Model Administrative Compliance Strategy in order to assist jurisdictions in developing, improving and implementing their own administrative compliance strategy to ensure the effectiveness of the Standard for Automatic Exchange of Financial Account Information in Tax Matters (AEOI). Read more in this OECD item.
Global Forum welcomes two new observers
The Study Group on Asia-Pacific Tax Administration and Research and the Asian Infrastructure Investment Bank have become observers of the Global Forum on Transparency and Exchange of Information for Tax Purposes. Read more in this OECD item.
Other territories
International
International Tax News - Edition 119, May 2023
International Tax News is designed to help multinational organisations keep up with the constant flow of tax developments. Among the topics featured in this month's edition are: 1) New Zealand releases draft Pillar Two legislation; 2) South Africa moves forward with Pillar Two; 3) Canada's mandatory disclosure rules; and 4) Saudi Arabia establishes four new Special Economic Zones.
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. This edition, from 1 June, includes: 1) access to a new African indirect tax guide with useful information across 43 countries including tax measures directed at the digital economy; 2) We also note that Israel has dropped VAT plans for B2C digital services.
Digital tax megabyte for May 2023
This edition, to the end of May includes: 1) access to the recording of our latest webcast of 25 April on Pillar Two; 2) our update on the IASB's accounting changes for Pillar Two and the news that our summary Pillar Two tracker now covers around 95 countries with some new display options; 3) Swiss consultation on a one-stop shop across cantons for Pillar Two; 4) a court challenge to the EU's Directive on Pillar Two; 5) proposals for US retaliatory measures that might apply to the UTPR and other unilateral measures like digital services tax (DST) levied by other countries; 6) updates on Digital Asset Tax in the Kenyan Budget (and a reminder about the scope of the new e-invoicing rules) and US state tax on digital content; 7) New Zealand's Budget provided an opportunity for the Government to remind us it would consider unilateral action if there was no agreement on Pillar One; 8) We also note the publication of proposals for EU customs reform which would probably affect the obligations of online platforms.
Environmental, Social and Governance (ESG)
- Considerations for accessing high-quality carbon offsets as part of the Net Zero transition
As businesses become more focused on their transition to Net Zero, many have turned to voluntary carbon offsets as part of their decarbonisation strategy. With pressure to make progress towards Net Zero intensifying, and businesses realising the commercial value in decarbonisation, demand for carbon offsetting is likely to accelerate. When coupled with a more restricted supply, this could lead to significant price rises. Read more. - Good Growth for Cities 2023
The Demos-PwC Good Growth for Cities report looks at how the radical reshaping of public and private sector roles would help our cities respond to current challenges, while at the same time steer us towards growth and genuine levelling up. Read our report and explore the data here. - Talking ESG: Moving from compliance to sustainable value
In this podcast, we discuss how having a comprehensive governance strategy for sustainability issues helps companies enhance value in the long-term.
Australia
Draft ATO Guidance on cross border intangibles arrangements - PCG 2023/D2
The Australian Taxation Office (ATO) has released a draft Practical Compliance Guideline, PCG 2023/D2 (the draft PCG), on intangibles arrangements involving international related parties. This draft PCG replaces PCG 2021/D4 which was released in May 2021. Read more in this PwC Tax Alert.
Belgium
See here for latest updates.
Brazil
TP Podcast: Brazil’s transfer pricing rules: A shift to international standards
In this TP Talks episode, Ugo Cannavale (Transfer Pricing Leader for PwC Italy), Michela Chin (Transfer Pricing leader for PwC Brazil), and Matias Pedevilla (Transfer Pricing Principal with PwC US and global leader of PwC's Global Coordinated Documentation service) discuss the overhaul of Brazil’s transfer pricing system, focusing on the main changes that have been introduced, the implications of the pending rules for multinationals, and what companies should be doing now.
Cyprus
Cyprus-Netherlands double tax treaty: will enter into force on 30 June 2023
The Cyprus Ministry of Finance announced on 18 May 2023 that the double tax treaty between Cyprus and the Netherlands will enter into force on 30 June 2023 and therefore the effective date should be 1 January 2024. Read more in this PwC Tax Alert.
Germany
Freshly Served: Germany’s latest Pillar Two Draft
In this episode from 24 May, Doug McHoney (PwC's International Tax Services Global Leader) is joined in Madrid by Arne Schnitger, International Tax Partner with PwC Berlin and host of the German podcast Frisch Serviert (Freshly Served). They dive into the German legislative process, compliance and reporting, the German QDMTT, deviations from the OECD Model Rules, as well as the interaction with the US GILTI regime. They also discuss Arne’s recent article, “Does the 'Initial Phase Relief' Make the EU’s Pillar Two Directive Invalid?
India
Changes in angel tax provisions – specified class of investors and start-up companies exempt; draft valuation rules open for public comments
Section 56(2)(viib) of the Income-tax Act, 1961 provides for taxing excess of the aggregate consideration received by specified companies from the resident investors over the fair market value of shares, if such consideration received exceeded the face value of the shares. Through the Finance Act, 2023, this section has been amended to include the consideration received from non-resident investors as well. The Central Board of Direct Taxes (CBDT) recently issued a press release proposing changes to rule 11UA of the Income-tax Rules, 1962 for the valuation of shares for the purpose of section 56(2)(viib) of the Act. In the press release, CBDT also proposed to exclude certain classes of non-resident investors and companies, to be notified, from the applicability of section 56(2)(viib) of the Act. Read more in this PwC Tax Insights.
Guidelines and notification to withhold tax on ‘net winnings’ from online games
The Finance Act, 2023 inserted section 194BA in the Income-tax Act, 1961 with effect from 1 April 2023. This provision stipulates an obligation on any person responsible for paying to any other person any income by way of winnings from any online game during the financial year (FY) to deduct tax on the net winnings in the person’s user account. According to section 194BA of the Act, tax is required to be deducted at the time of withdrawal and at the end of the FY. Taxpayers were awaiting clarifications on the mechanism to compute the amount of ‘net winnings’. The Central Board of Direct Taxes (CBDT) has now issued guidelines exercising the powers given in the section. Read more in this PwC Tax Insights.
Japan
Japan updates its Administrative Guidelines on the Mutual Agreement Procedure based on the BEPS Action 14 Final Report “Making Dispute Resolution Mechanisms More Effective”
This PwC news alert describes the BEPS Action 14 Final Report recommendations for securing taxpayers’ access to mutual agreement procedure (MAP) and provides an overview of the revisions to the Administrative Guidelines on the Mutual Agreement Procedure in Japan based on these recommendations.
Middle East
UAE
- Corporate Tax: Ministerial Decisions No. 114 & 115 releases
On 9 May 2023, the Ministry of finance (‘MoF’) issued Decision No 114 of 2023 on the Accounting Standards and Methods for the Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses (hereinafter referred to as the ‘CT Law’). Moreover, the MoF issued on 10 May 2023 Decision No 115 of 2023 on Private Pension Funds and Private Social Security Funds for the Purposes of the CT Law. Both Decisions came into effect the day following their publications. Read more in this PwC Tax Alert. - Corporate Tax: Ministerial Decision No. 116 of 2023 Release Participation Exemption
On 10 May 2023, the Ministry of finance issued Decision No 116 of 2023 with regards to the Participation Exemption for the Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses (hereinafter referred to as the ‘CT Law’). This Decision came into effect the day following its publication. Read more in this PwC Tax Alert. - CT - Cabinet Decision No.49 of 2023
On 8 May 2023, the Cabinet of Ministers issued Decision No. (49) of 2023. This Decision specifies the categories of Businesses or Business Activities conducted by a resident or non-resident natural person that are subject to Corporate Tax under Federal Decree-Law No. (47) of 2022 on the Taxation of Corporations and Businesses (the ‘CT Law’). This Decision comes into effect on 1 June 2023. Read more in this PwC Tax Alert.
Saudi Arabia: Updates regarding the Service PE concept
On 17 May 2023 the Zakat, Tax and Customs Authority (ZATCA) released a new publication regarding the Taxation of Permanent Establishments (PEs) in the context of the double tax treaties. This includes the taxation of different types of the PEs as Fixed Place of Business, Agency PE, Service PE etc. Read more in this PwC Tax Alert.
Oman: Double tax treaty between Oman & Egypt
During the visit of His Majesty Haitham bin Tariq, the Sultan of Oman, to Egypt, Oman and Egypt signed a double tax treaty on 22 May 2023. The signing of this treaty is anticipated to encourage capital investment, trade in goods and services and other economic activities between the two nations by preventing international double taxation. Read more in this PwC Tax Alert.
Netherlands
Cyprus-Netherlands double tax treaty: will enter into force on 30 June 2023
The Cyprus Ministry of Finance announced on 18 May 2023 that the Double Tax Treaty between Cyprus and the Netherlands will enter into force on 30 June 2023 and therefore the effective date should be 1 January 2024. Read more in this PwC Tax Alert.
New Zealand
Budget 2023 tax measures
As reported in our previous edition, on 18 May New Zealand published its 2023 Budget and Taxation Bill, which included revenue estimates and measures to implement Pillar Two. This PwC TaxTips Alert outlines the Government's key tax announcements on Budget Day. As noted in our Digital tax megabyte for May 2023, New Zealand's Budget also provided an opportunity for the Government to remind us it would consider unilateral action if there was no agreement on Pillar One.
New UK free trade deal with New Zealand in force
The new free trade agreement between the UK and New Zealand entered into force on 31 May 2023. New Zealand will benefit from 97 percent of tariffs being removed immediately, with tariffs to be further eased on agricultural goods after five years. New Zealand will waive tariffs on UK goods immediately.
Spain
Spain confirms the completion of its internal procedures for the entry into effect of the provisions of the MLI under Article 35(7)
This document contains all of the notifications made by the Kingdom of Spain confirming the completion of its internal procedures for the Covered Tax Agreements identified in this document pursuant to Article 35(7)(b) of the Convention.
Sweden
Transfer pricing documentation - important for tax surcharge decisions
The Administrative Court of Appeal’s (“kammarrätten”) judgment contradicts the Swedish Tax Agency’s guidance on the significance of a company’s transfer pricing documentation for the decision on tax surcharges. Read more in this PwC tax blog.
Switzerland
For the latest updates on current topics, see this PwC Switzerland Insights page.
Switzerland to set up one-stop shop in Pillar Two adoption plan
Switzerland is seeking input on a proposal to minimise the administrative burden for multinational enterprises with business units across multiple Swiss cantons under a new supplementary tax regime aligned with OECD global minimum tax rules. See our Digital tax megabyte for May 2023 (item 3).
US
House Republicans introduce Bill responding to Pillar Two and unilateral taxes
House Ways and Means Committee Chairman Jason Smith (R-MO) and all Ways and Means Republicans have introduced the Defending American Jobs and Investment Act. The proposed legislation would increase income tax and withholding tax rates, initially by 5 percentage points, increasing up to 20 percentage points on certain foreign citizens, foreign corporations, and foreign partnerships of any foreign country that is listed in a report on the extraterritorial taxes and discriminatory taxes of foreign countries submitted by the Secretary of the Treasury to certain Congressional committees. See this PwC Tax Insights.
IRS GLAM addresses the 5% FIRPTA exception for publicly traded stock held via a partnership
Generally, shares held in a US Real Property Holding Company are treated as US Real Property Interests. However, an exception applies if the shares are publicly traded in the case of a person that holds 5% or less of the publicly traded shares. Previously, there had not been any guidance on how to apply the exception in the case of shares held by a partnership. However, on 19 May, the IRS released a generic legal advice memorandum concluding that the 5% threshold for the Publicly Traded Exception applies at the partnership level. This issue has particular relevance for private equity investors, which often hold interests in US corporations through partnerships. Read more in this PwC Tax Insights.
Tax Court finds ‘tax affecting’ appropriate for S corporation valuation
In Cecil v. Commissioner (TC Memo 2023-24), the US Tax Court upheld the use of ‘tax affecting’ to determine the value of S corporation shares for Federal gift tax purposes. ‘Tax affecting’ is a valuation approach that applies a hypothetical entity-level tax to a pass-through entity’s taxable income, which reduces the value of the business. Read more in this PwC Tax Insights.
- Latest on OECD project; What's next after debt limit deal?
In this episode from 30 May, Will Morris shares the latest on Pillars One and Two, including the staggered implementation of Pillar Two and recent US developments. Rohit Kumar dives into the debt limit agreement reached over the weekend and walks through what’s next and addresses taxpayer concerns. - Large taxpayers: Prepare now for increased compliance
In the midst of debt limit talks, Congressional tax writing committees also have focused on IRS funding, which was bolstered by the Inflation Reduction Act. In this episode from 22 May, Beth Tucker urges taxpayers to prepare now for increased compliance and audit. Rohit Kumar joins to talk about the latest on debt limit talks. - Week in Review
- In this episode from 2 June, Rohit Kumar discusses the successful passage of the bipartisan debt limit legislation days before the default date. He encourages companies to turn their focus to the Ways and Means Republicans' economic growth package expected to be released in the coming days.
- Will they or won’t they? In this episode from 26 May Todd Metcalf answers the burning question in Washington about an agreement on raising the debt ceiling as time – and Treasury’s cash drawer – runs out. Looking ahead, taxpayers should keep their eyes on debt limit negotiations.
Tax Readiness webcast series
Tax Readiness: Q2 Financial reporting considerations
Join our panel of PwC specialists on Thursday 22 June at 7pm, as they take a deep dive into key tax accounting and reporting reminders, along with recent tax developments. Register here.
State and local tax
- COST Forum on US State and Local Taxes for European Companies - London 20 June 2023
PwC is one of the sponsors of the COST Forum on US State and Local Taxes for European Companies, a one day conference on US State and Local Taxes for European companies that will be held in our Embankment Place office in London on 20 June 2023. Leading practitioners with dedicated knowledge in this area, including our very own Rob Ozmun and Dorothy Lo, will help attendees understand the tax requirements and risks of doing business or expanding into the vastly lucrative US market. Differences between the US and European tax systems will be covered and attendees will learn about threshold issues such as nexus and jurisdiction. You can find the agenda and registration link here. - Minnesota enacts retail delivery fee, effective 1 July 2024
Enacted transportation legislation in Minnesota includes a 50-cent retail delivery fee, new metro area sales and use taxes, and increased fuel taxes. The retail delivery fee is effective 1 July 2024. Read more in this PwC Tax Insights. - Minnesota enacts income, pass-through, investment, and sales tax changes
H.F. 1938, enacted on 24 May, makes several changes to the corporate income tax applicable starting with the 2023 tax year, including a reduction in the state’s DRD percentages, subjecting a taxpayer’s GILTI to tax, and decreasing from 80% to 70% the amount of taxable net income on which NOLs can be applied. Read more in this PwC Tax Insights. - Tennessee enacts changes to franchise and excise, business, and sales taxes
H.B. 323, the Tennessee Works Tax Act, was enacted on 11 May. Changes to the business tax include: 1) an exemption for sales made from a manufacturing location or nearby storage or warehouse facilities; 2) a reduction in the rate for Class 5 taxpayers; and 3) an increase in the minimum level of taxable sales necessary to be subject to the tax. Read more in this PwC Tax Insights.
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.
Vietnam
Vietnam ratifies the BEPS MLI
Vietnam has deposited its instrument of ratification for the BEPS multilateral instrument. The BEPS MLI will enter into force for Vietnam from 1 September 2023.