Two weeks to 21 April 2023
Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK.
UK
Tax Administration and Maintenance Day
At Spring Budget 2023, the government announced that it would bring forward a further set of tax administration and maintenance announcements at a Tax Administration and Maintenance Day. The government now has confirmed it will set out these announcements on Thursday 27 April and outline the action it is taking to simplify the tax system, tackle the tax gap and modernise the tax system.
Finance Bill 2023
The Finance Bill is currently progressing through its Committee Stage and is not anticipated to complete its Commons stages until mid-June at the earliest. The Bill will not become substantively enacted for UK GAAP and IFRS purposes until it does so. It will then go through its Lords stages, with Royal Assent expected at some point between late June to late July, before Parliament closes for the summer recess on 21 July. The Finance Bill will not be fully enacted for US GAAP purposes until that point. The full text of the amendments are available here.
Pillar Two
- Pillar Two webcast: When Tax Policy Meets Implementation. Administrative guidance, readiness, and compliance issues
On this webcast taking place on Tuesday 25 April at 1pm UK time, our tax policy specialists will review unresolved technical issues, as well as the administrative guidance to date. We will also discuss how countries are implementing the rules, and how businesses can deal with what we know and don’t know. In the latter category, one big question is what is being built into the regime for increasing tax certainty during the transition and beyond? Tuesday 25 April at 1pm UK time. You and your clients can register here.
For further information regarding the implementation of Pillar Two, visit our Pillar Two hub - Pillar Two Country Tracker
PwC’s Pillar Two Country Tracker is now available directly on our Pillar Two global website. This free tracker provides the status of Pillar Two implementation in different countries and regions.
MDR cross-border arrangements guidance updated
As noted in our last edition, the DAC6 service will close on 31 May 2023. To tell HMRC about any reportable arrangements from 28 March 2023, use the new Mandatory Disclosure Rules service. You can still use the DAC6 service until 31 May 2023 to tell HMRC about arrangements that became reportable before 28 March 2023, or to send additional information, replacements or deletions for previously sent disclosures. Check here if you need to tell HMRC about a cross-border arrangement.
Corporate Interest Restriction
- Corporate Finance Manual updates
HMRC has updated the following sections following review: - CFM96320 - Interest restriction: related parties: ordinary independent financing arrangements by banks and others
- CFM96080 - Interest restriction: group-interest: derivative contracts: application of the Disregard Regulations
- CFM96070 - Interest restriction: group-interest: derivative contracts: overview
- CFM56050 - Derivative contracts: tax avoidance: transfer pricing and derivative contracts
Research and Development (R&D)
- The Finance Bill amendment paper is available here. For R&D amendments, see Government amendment 14 on page 2 to schedule 1.
- Consultation outcome Draft guidance: Research and Development (R&D) tax reliefs
HMRC have concluded their consultation on draft guidance covering reforms to research and development (R&D) tax reliefs from 1 April 2023. The updated guidance, will be formally published as part of the Corporate Intangibles Research and Development Manual once the Finance Bill receives royal assent in summer 2023. - Update: Tell HMRC that you’re planning to claim Research and Development (R&D) tax relief
HMRC have updated their guidance to amend the dates in example 1 and example 2 in the section 'When you must notify by' have been amended to show the correct periods of account and submission dates.
Case law update
- UK taxation of a foreign dividend paid in part out of capital
In Buckingham v HMRC [2023] UK FTT 358 (TC), the First-Tier Tribunal considered the UK taxation of a ‘special dividend’ that had been paid by a Delaware incorporated company partly out of earnings and profits and partly out of capital. The FTT quashed the HMRC review decision that sought to tax the full amount of the dividend as income and also ruled that HMRC’s discovery assessment was, in any event, out of time. See paragraph 120 and onwards for a reminder of the principles governing the taxation of foreign dividends in the light of the First Nationwide decision. - Time limit for DTR claim under double tax treaty
In Sikder v HMRC [2023] UK FTT 362(TC), a Bangladeshi taxpayer was seeking to make a claim for double tax relief under the UK-Bangladesh double tax treaty. HMRC considered the claim as out of time, but the taxpayer claimed that the time limit set out in s43 TMA 1970 did not apply to his claim because that limitation was only applicable to British citizens. As there was no time limit specified in the treaty itself, the taxpayer asserted that his claim was not out of time. The FTT rejected this argument, on the basis that double tax treaties are given effect in UK law by s6 TIOPA 2010 and have effect in accordance with s6(2) - (4) where the claim is being made to HMRC, regardless of the citizenship of the claimant. - Preliminary issues considered re Danish tax authority withholding tax
In Skatteforvaltningen (the Danish Customs and Tax Administration) v Solo Capital Partners LLP & Ors [2023] EWHC 590, the High Court ruled on various preliminary issues concerning a claim for damages made by the Danish tax authority in respect of refunds of Danish dividend withholding tax paid out as the result of allegedly fraudulent applications.
Treaty updates
- UK/Kyrgyzstan: new double tax treaty enters into force
The Kyrgyzstan-United Kingdom double tax treaty entered into force on 17 March, according to information recently published on the Foreign, Commonwealth & Development Office webpage.
HMRC Manual updates
In addition to the changes referred to above (regarding CIR and R&D), the following changes have also recently been made:
- International Manual - DPT
HMRC has updated the following sections following review:- INTM489836: Diverted Profits Tax: customer engagement with HMRC: initial contact between customers and HMRC.
- INTM489996: Diverted Profits Tax: appendix A - notification template guidance
- Capital Gains Manual - UK property rich investment vehicles
HMRC has updated the following sections following review:- CG15400P - Capital Gains manual: introduction and computation: computation: capital allowances: contents
- CG73997M - UK property rich collective investment vehicles: Interaction with other TCGA92 provisions: Disapplying the ‘appropriate connection’
- CG-APP18-250 - “Report and pay the tax” section of the return submitted through the CGT on UK Property Account: Enter losses and exemptions
- Digital Services Tax Manual
HMRC has updated the following section following review:- DST18300 - Online Marketplace - Condition A
EU
EU refers Belgium to the CJEU for failing to correctly transpose the Anti-Tax Avoidance Directive
The European Commission has decided to refer Belgium to the Court of Justice of the European Union for failing to correctly transpose the Anti-Tax Avoidance Directive (Directive (EU) 2016/1164). Read more in this EU press release.
Crypto-assets - Green light to new rules for tracing transfers in the EU
On 20 April, the European Parliament endorsed the first EU rules to trace crypto-asset transfers, prevent money laundering, as well as common rules on supervision and customer protection. Read more in this EP press release.
Complexity of MNE structure linked to profit shifting
Multinational enterprises with complex ownership structures exhibit a pattern of shifting profits between subsidiaries, whereas MNEs with simpler ownership structures do not, according to a new EU Tax Observatory paper.
Stopping the flow of dirty money: Parliament ready for negotiations
MEPs will open talks with the Council of the EU on reforming the EU’s anti-money laundering rules to help authorities crack down on the illicit flow of money and assets. Read more in this EP press release.
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 17 April includes: 1) EU Commission Adopts Regulation on Tax Transparency; 2) EU Parliament MEs Adopt Position on EU AML Legislation; 3) International Fiscal Association Invites Views on Tax Avoidance in Advance of European Conference (5 – 7 July); 4) EESC Adopts Opinion Supporting DAC8 Proposal; and 5) Register Now: CFE Forum – 20 April 2023 – ‘Towards a More Cohesive European Fiscal Union? Minimum Tax & VAT in the Digital Age’. 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.
- IASB confirms temporary relief from deferred tax accounting following OECD Pillar Two tax reform
The International Accounting Standards Board (IASB) decided on 11 April to finalise amendments to IAS 12 Income Taxes following the Pillar Two model rules published by the Organisation for Economic Co-operation and Development (OECD). The amendments, approved in a special supplementary meeting, will provide temporary relief for companies from having to account for deferred taxes arising from the implementation of the Pillar Two model rules. See this IFRS news release. - PwC’s Pillar Two Country Tracker is now available directly on our Pillar Two global website. The tracker is free to access and will help your clients and targets understand the status of Pillar Two developments around the world.
- Pillar Two webcast: When Tax Policy Meets Implementation. Administrative guidance, readiness, and compliance issues
On this webcast taking place on Tuesday 25 April at 1pm UK time, our tax policy specialists will review unresolved technical issues, as well as the administrative guidance to date. We will also discuss how countries are implementing the rules, and how businesses can deal with what we know and don’t know. In the latter category, one big question is what is being built into the regime for increasing tax certainty during the transition and beyond? You and your clients can register here.
Zimbabwe Joins OECD Global Forum On Tax Transparency
Zimbabwe recently joined the Global Forum on Transparency and Exchange of Information for Tax Purposes, becoming its 167th member and 36th African member. Read more in this OECD item.
Mongolia commits to start automatic exchange of financial account information by 2026
Mongolia has committed to implement the international Standard for Automatic Exchange of Financial Account Information in Tax Matters (AEOI) by 2026. Mongolia’s Minister of Finance said “This is an important step in providing a level playing field for all taxpayers and showcasing Mongolia as a responsible and trustworthy member of the global financial community." Read this OECD item.
Income-based tax incentives for R&D and innovation
Tax incentives that provide preferential tax treatment to the incomes arising from research and development (R&D) and innovation activities, such as intellectual property regimes, have become widespread in recent years. This OECD working paper describes the key design features of tax incentives available in 49 member countries of the Inclusive Framework on BEPS (IF), covering all OECD countries and EU countries.
Other territories
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 13 April, includes: 1) comment on plans from the UN Tax Committee in relation to a possible Subject To Tax Rule (STTR) and for a Fast Track Instrument procedure for this and other digital treaty updates; 2) Ireland and Canadian announcements about Pillar 2 legislation as well as, in Canada's case, Pillar 1 and its planned Digital Services Tax (DST); 3) Kenya's intention to repeal it's DST in favour of Pillar 1; 4) New Zealand has now passed its law changes to introduce reporting and GST changes for various online platforms; 5) penalties for breaching the Taiwan rules are about to kick in; 6) Egypt has published guidelines on new digital supplier VAT registration rules; and 7) there are further US state tax developments reported for Alaska and Maryland.
TP Podcast: The endgame begins – Navigating TP implications in the coming Pillar Two world
This TP Talks episode is part 3 of a three-part series on Pillar Two, where Ugo Cannavale (Transfer Pricing Leader for PwC Italy), Kartikeya Singh (Transfer Pricing Principal in PwC’s US National Tax Services practice), and Giorgia Maffini (Transfer Pricing and Tax Policy Director with PwC UK) discuss the latest Pillar Two developments, country level developments, and what companies need to prioritize from a transfer pricing perspective.
Environmental, Social and Governance (ESG)
- Driving change through supply and value chain
Driving change means transitioning to a circular economy, where carbon is designed out of the value chain and energy efficient resources are kept in use for as long as possible. Read more. - Managing nature risks: From understanding to action
Business relies heavily on nature to supply much-needed goods and services. Recognizing those dependencies is the first step toward managing the risks and opportunities they create. Explore PwC's recent report “Managing nature risks: From understanding to action” to find out more.
Australia
Proposed new Public Country by Country Reporting
As reported previously, the Australian government has released draft legislation to require certain large multinationals (known as Country by Country (CbC) reporting parent entities) to publicly disclose the information in their CbC reports broken down by jurisdiction, as well as publicly disclose other new tax and financial information. Read more in this PwC Alert.
Belgium
EU refers Belgium to the CJEU for failing to correctly transpose the Anti-Tax Avoidance Directive
The European Commission has decided to refer Belgium to the Court of Justice of the European Union for failing to correctly transpose the Anti-Tax Avoidance Directive (Directive (EU) 2016/1164). Read more in this EU press release.
Egypt
Egypt publishes guidelines on new digital supplier VAT registration rules
The Egyption Government has published guidelines on the process by which non-resident and unregistered persons without a permanent establishment in Egypt and supplying remote services to Egyptian consumers (B2C) above the registration threshold, will be obliged to register and account for 14% VAT using the ‘Simplified Vendor Registration System’. Read more in the latest digital tax byte.
Germany
Waiver of exit tax upon return to Germany
According to a decision of the Supreme Tax Court, the exception from the exit taxation due to an "only temporary absence" must be granted if the taxpayer again becomes subject to unlimited income tax within five years after leaving Germany and irrespective whether he had from the outset the intention to return. Read more in this PwC blog.
Hong Kong
Proposal to refine Hong Kong’s FSIE regime for foreign-sourced disposal gains unveiled
The foreign-sourced income exemption (FSIE) regime will be refined to include disposal gain on other types of assets (in addition to equity interests) to align with the latest requirements of the European Union (EU). On 6 April 2023, the Financial Services and Treasury Bureau (FSTB) issued the consultation paper Refinements to Hong Kong’s Foreign-sourced Income Exemption Regime for Foreign-sourced Disposal Gains. The Consultation Paper sets out the proposed refinements to the FSIE regime initially formulated by the Government based on its discussion with the EU thus far. This PwC news flash summarises the proposed refinements and our observations.
Bill on taxation of insurers upon implementation of Risk-based Capital regime
The Insurance (Amendment) Bill 2023 (Bill) was gazetted on 6 April 2023. The Bill seeks to amend the Insurance Ordinance (Cap. 41) (IO) to provide a legal framework for the implementation of a Risk-based Capital (RBC) regime for the Hong Kong SAR insurance industry. This PwC news flash summarises the key observations on the proposed amendments to the IRO.
India
Revisionary proceedings alleging PE of a non-resident on offshore supply of goods quashed, citing no error in the assessment order
The Delhi bench of the Income-tax Appellate Tribunal has quashed the revisionary order issued by the Commissioner of Income-tax for assessment year 2014–15. It holds that, as the impugned transaction for offshore supply of goods was pending before the Authority for Advance Ruling for adjudication and the Tax Officer (TO) carried out a detailed inquiry during the assessment proceedings, the assessment order cannot be held as erroneous and prejudicial to the interest of the Revenue. Read more in this PwC Tax Insights.
LoB test in depth examined to hold that payment towards advertising and sponsorship rights does not qualify as ‘royalty’ under India-Malaysia double tax treaty
The Mumbai bench of the Income-tax Appellate Tribunal has rejected the invocation of the Limitation of Benefits (LoB) clause by the Indian Revenue authorities against a Malaysian company under the India-Malaysia double tax treaty. Read more in this PwC Tax Insights.
Consideration is critical to levy service tax on corporate guarantee provided to group companies
The Supreme Court has rejected the civil appeal preferred by the Revenue authorities and affirmed the decision of the Customs Excise and Service Tax Appellate Tribunal (CESTAT) in which it was held that the issuance of corporate guarantees to group companies, without consideration, is not a taxable service under the Finance Act, 1994. Read more in this PwC Tax Insights.
Comparability issues in TP can give rise to ‘substantial question of law’
In a significant decision, the Supreme Court has overturned a batch of High Court decisions to hold that the determination of arm’s length price (ALP) must follow the guidelines stipulated under Chapter X of the Income-tax Act, 1961 and the relevant rules thereunder, and any deviation from these guidelines can be considered perverse and subject to scrutiny by the High Courts. Therefore, the High Courts can examine whether the guidelines under Chapter X of the Act are followed or not, and whether the findings recorded by the Tribunal while determining ALP are perverse or not. Read more in this PwC Tax Insights.
Korea
Korean Tax Update - April 2023
The latest edition covers: 1) Special Tax Treatment & Control Law amended to expand tax credits for national strategic technologies and reintroduce temporary investment tax credit; 2) Korea and Andorra reach an agreement and initial the income tax treaty for the avoidance of double taxation; 3) Korea’s Tax Expenditure Plan for 2023; and 4) Rulings update.
Kyrgyzstan
UK/Kyrgyzstan: new double tax treaty enters into force
The Kyrgyzstan-United Kingdom double tax treaty entered into force on 17 March, according to information recently published on the Foreign, Commonwealth & Development Office webpage.
Luxembourg
Upcoming changes to Luxembourg tax procedures
The Luxembourg finance minister recently tabled draft law n° 8186 in parliament proposing several changes to the Luxembourg law governing procedures in relation to direct taxes, the Abgabenordnung (AO). The law would create new obligations for taxpayers, however, a modernisation of the AO and a reinforcement of taxpayers´ rights are still missing. Read more in this PwC news item.
Middle East
Saudi Arabia
- Establishment of four new Special Economic Zones
On 14 April 2023, the Saudi government announced the establishment of four new Special Economic Zones (SEZs) across various regions of the country which aim to offer competitive incentives for businesses who will invest in such zones. Read more in this PwC Alert. - ZATCA extends transfer pricing regulations to Zakat payers and introduces an APA program
The Board of Directors of Zakat, Tax, and Customs Authority (ZATCA) in the Kingdom of Saudi Arabia recently announced the approval of the proposed amendments to the Transfer Pricing Bylaws to bring the following into effect: 1) Extend applicability of the Transfer Pricing (TP) provisions to Zakat payers; and 2) Introduce Advance Pricing Agreements (APA) provisions for Tax payers and Zakat payers. The amendments will be applicable for Financial Years (FYs) starting on or after 1 January 2024. Read more in this PwC Alert.
United Arab Emirates
- Ministerial Decision No. 43 of 2023 Release: Exception from CT Registration
The United Arab Emirates has issued Ministerial Decision No. 43 of 2023, which sets out which businesses are exempt from the requirement to register for corporate income tax. Read more in this PwC Alert. - Small Business Relief for Corporate Tax Purposes
The United Arab Emirates Ministry of Finance has issued Ministerial Decision No. 73 of 2023 regarding details on the Small Business Relief under the country's new corporate income tax regime. Read more in this PwC Alert. - Key UAE CT considerations for financial institutions
A number of complexities can arise in relation to mainland UAE entities, freezone entities operating in the UAE and UAE branches of foreign banks, in relation to their tax position once the CT law becomes effective. This PwC Alert summarises a number of key UAE CT considerations.
Mongolia
Mongolia commits to start automatic exchange of financial account information by 2026
Mongolia has committed to implement the international Standard for Automatic Exchange of Financial Account Information in Tax Matters (AEOI) by 2026. Mongolia’s Minister of Finance said “This is an important step in providing a level playing field for all taxpayers and showcasing Mongolia as a responsible and trustworthy member of the global financial community." Read this OECD item.
New Zealand
Tax Policy Bulletin - April 2023
This edition covers: 1) Tax Bill receives Royal assent ; 2) Inland Revenue consults on the tax treatment of crypto assets when paid as remuneration to employees; 3) Use of money interest rates to increase SaaS configuration and customisation costs - Inland Revenue consults on draft interpretation guidelines; 4) Draft guidance on deductibility of holding costs for land; 5) Inland Revenue releases report on application of the interest deductibility rules for build-to-rent developments; and 6) Round-up of open consultations, recent tax cases, and other recent developments.
South Africa
PwC South Africa Tax Synopsis - March 2023
This edition includes: 1) Requesting the remission of interest post the conclusion of a voluntary disclosure programme application; 2) Diesel refund system for manufacturers of foodstuffs; and 3) SARS watch.
Switzerland
For the latest updates on current topics, see this PwC Switzerland Insights page.
Taiwan
Taiwan penalties imminent for online platform reporting discrepancies
Following changes to the rules affecting business sellers using an online platform, the Ministry of Finance (MOF) allowed a grace period from 1 January 2023 to 30 April 2023, during which business entities that fail to comply with the new regulations would not be subject to penalties. Read more in the latest digital tax byte.
Thailand
Pillar Two global minimum tax rules to be adopted in Thailand
The Thai Cabinet recently approved measures to introduce the global minimum tax rules in Thailand. According to the Cabinet resolution, the draft Pillar Two rules are intended to be introduced in 2023 and may become effective in 2025. However, at this stage the details and components of the rules are yet to be announced. Read more in this PwC Alert.
US
Threading the Needle: Pillar Two and the IRA’s Green Energy Credits
In this Cross-border Tax Talks episode from 19 April, Doug McHoney (PwC's US International Tax Services Global Leader) is joined by Pat Brown, seven-time veteran of the podcast, and co-leader of PwC’s WNTS practice, to discuss green energy credits and Pillar Two administrative guidance.
IRS Strategic Operating Plan identifies priorities for improved services, compliance
The IRS has released its FY 2023 to 2031 Strategic Operating Plan, setting forth a framework for how the IRS plans to use the $79.4 billion in additional funding provided by the Inflation Reduction Act to transform tax administration and services provided to taxpayers and tax professionals. Read more in this PwC Tax Insights. See also the Policy on Demand episode from 12 April on this topic, set out below.
IRS Notice provides relief for certain 2019 refund claims
Notice 2023-21 provides that the period during which the due date of 2019 tax returns was postponed by Notice 2020-23 will be disregarded for the 3-year lookback period. Read more in this PwC Tax Insights.
Policy on Demand series
- Hearings may highlight need for more IRS detail on budget and green energy incentives
Congress is returning from a two-week recess. In this episode from 17 April, Chairman Dave Camp joins us to discuss priority issues as Congress returns, including a Republican debt limit proposal and hearings on IRS spending and implementation of green energy incentives. - IRS Strategic Operating Plan: Missing key details
The IRS recently released a Strategic Operating Plan setting forth a framework for how it plans to use nearly $80 billion in additional funding provided by the Inflation Reduction Act. In this episode from 12 April, Kevin Brown discusses the plan and what it means for taxpayers. - Week in Review
- In this episode from 21 April, Pam Olson discusses how Congress must address the debt limit before moving forward with other legislation. Companies should focus on Congressional action around expiring tax provisions and Treasury IRA guidance.
- In this episode from 14 April, Rohit Kumar discusses how a House Republican bill may seek to jump start debt limit negotiations. Companies concerned about the extension of expired TCJA provisions may see relief in end-of-the-year legislation.
Tax Readiness webcast series
- Tax Readiness: Demystifying the data dilemma - How tax can stay ahead of constant change
Consistent, reliable data is the pinnacle of success and a critical component in building operational readiness in tax. It can help manage reporting obligations, alleviate internal and external demands, and serve as the cornerstone of compliance and implementation for required changes (eg Pillar Two). Watch this webcast replay from 18 April to join our panel of specialists for a “how to” discussion on realising a future-ready, data-driven tax function powered by a new baseline of capabilities. - Tax Readiness: Q1 Financial reporting considerations
Register here to watch the replay from 28 March where our panel of PwC specialists take a deep dive into key tax accounting and reporting reminders and discuss recent tax developments. - Tax Readiness: Deals Outlook - The tax perspective
In this webcast from 2 March, our panel reviews the recently launched US Deals 2023 outlook and discusses key tax issues and opportunities including the new stock buyback excise tax, divestitures, expiring provisions, and state and local taxes. Watch the replay here.
State and local tax
- Tax Readiness: 5 years later - The impact of Wayfair and tax reform on state taxation
It has been almost five years since the US Supreme Court decided South Dakota v. Wayfair and struck down the long standing “physical presence” nexus test, and a little more than five years since the Tax Cuts and Jobs Act rewrote the federal income tax laws for the first time since 1986. Register here to join our panellists on Tuesday 25 April at 7pm as they discuss the evolving compliance challenges produced by these two events and how companies are implementing leading practices to reduce costs, minimise risk, and produce cash tax savings. - Alaska proposes market apportionment for “digitalised services”
Alaska proposed legislation (S.B. 122), introduced on 3 April 2023, would apply single sales factor apportionment to the income of taxpayers engaged in “a highly digitised business in the state”. A taxpayer would be deemed to be engaged in “a highly digitised business in Alaska when 50% or more of its in-state sales consist of any combination of sales of: IP, services related to computers, tangible personal property delivered from internet sales and many more. Read more in the latest digital tax byte. - Maryland DST court proceedings continue in Supreme State court
Briefs were filed on 31 March 2023 in the Maryland Supreme State court in Comptroller v Comcast, according to the deadlines established in January. They argue that the Court should uphold the lower court ruling that the Maryland state DST was an unconstitutional violation of the Commerce Clause, the First Amendment, and the Internet Tax Freedom Act. Read more in the latest digital tax byte.
You and your clients 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
Draft proposal to revise CIT law
In March, the Ministry of Finance released a proposal to revise the Corporate Income Tax (“CIT”) law and has sought public comments in this respect. This PwC Newsbrief outlines some proposed key changes.
Zimbabwe
Zimbabwe Joins OECD Global Forum On Tax Transparency
Zimbabwe recently joined the Global Forum on Transparency and Exchange of Information for Tax Purposes, becoming its 167th member and 36th African member. See this OECD item.