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Back in 2021, the Irish government began an initial consultation on a territorial tax system. The purpose of the innovations is to exempt dividends received by Irish companies from foreign sources from corporation tax. If a legal entity receives dividends from another company in which it has a certain percentage of shares, then it will not pay tax on these dividends. This step is necessary to encourage investment and avoid double taxation. The roadmap presented by the government includes technical advice and invites stakeholders to answer 53 questions regarding the development of a dividend participation regime. These questions are divided into four main areas: Structural considerations (for example, the optionality of the existing tax-plus-credit regime). Indirect consequences (for example, alignment with existing benefits for foreign subsidiaries). Anti-avoidance rules (eg potential modification of Ireland's anti-hybrid provisions). Any other issues that must be taken into account when registering participation in foreign dividends. The current corporate tax system, which provides double tax relief on foreign dividends, often does not result in...

Despite a large number of objections and amendments from other parties and a veto by the President of Portugal, the parliamentary majority was able to achieve the entry into force of the "Mais Habitação" package of measures aimed at improving housing affordability. What is the final version of the main measures provided for in the amendments entering into force? Limits on rent increases under new contracts. The initial rent for new contracts for houses that have been on the rental market for the past five years cannot exceed 2% of the previous value. Family IMI deduction increases. It will be 30, 70 and 140 € for one, two and three or more dependents. Forced rental of empty housing, which applies to housing that has been empty for more than 2 years. Owners will have 90 days to start using it for housing or put it on the rental market. Capital gains tax exemption for housing sold to a municipality, which means the IRS is cleared when the property is sold to the state or municipalities. Cancellation of tax benefits under the IRC for investment funds participating in housing renovation. Extraordinary tax on short-term rental housing. AL (alojamento local) in...

A person who resides in Thailand for up to 180 days per year and receives foreign income from employment or assets will be subject to personal income tax under Section 48 of the Internal Revenue Code. This rule was announced by the Thai Tax Department on September 18. This has three specific targets: residents trading foreign stock markets through foreign brokerages, cryptocurrency traders and Thais who exploited a loophole that allowed them to bring foreign income into the country tax-free after holding it in an offshore account for more than a calendar year. “The principle of taxation is that you must pay tax on income you receive from abroad, regardless of how you earn it and regardless of the tax year in which the money is earned,” a Treasury source said , who wished to remain anonymous. The previous rule allowed residents with foreign income to be taxed only if the money was remitted to Thailand in the same year in which it was earned. The tougher measure is intended to close the door on deferring the remittance of foreign earnings to another year. The new rule, which will come into effect on January 1, 2024, will allow authorities to tax individuals' foreign...

Previously, married couples in Switzerland were taxed jointly. In most cases, married couples pay higher taxes because they file one joint return. When both spouses are high earners, they pay higher taxes. The amount of their income is subject to high tax rates. The guidelines are intended to implement an initiative that advocates individual taxation regardless of marital status. Under the proposed changes, married couples would file two separate tax returns and would be subject to the same rules as unmarried couples. Also, the amount of the child deduction applicable to direct federal tax will be increased from 6,600 to 12,000 francs. The process of introducing new principles of individual taxation will be gradual and the decrease in budget revenues will not be felt for several...

On September 13, 2023, a regional forum on GMT Pillar 2 was held in the UAE. During which it was decided to abandon the introduction of a minimum corporate tax in the Emirates in 2024. Although the UAE has joined the OECD initiative, the prospects for its introduction remain closed. Let us recall that in 2021 the OECD invited member countries to introduce the concept of a minimum corporate tax, setting the rate at no less than 15%. The joint final statement of the representatives of the UAE and the OECD did not look optimistic. The parties agreed that broad consultations on the introduction of GMT would continue in the Emirates, but the actual timing of this event was not specified. There is no official information. The new business tax scheme, adopted in the summer of 2023, increases the corporate tax rate to 9%, which is less than the threshold determined by the OECD. Perhaps the UAE is not interested in introducing GMT Pillar 2 or is considering this option, but in the distant...

In 2021, the Austrian government decided to implement tax reform. It provides for a gradual reduction in tax rates for individuals from 2022 to 2024. The goal of the reform is to increase incomes and purchasing power of the population, stimulate economic growth and create new jobs. On August 29, the Inflation Adjustment Decree for 2024 was published. The inflation rate calculated in accordance with local legislation is 9.9%. Taking this into account, according to section 33 (1a) of the Income Tax Law, the income limits of citizens that will be taken into account during the calculation of income tax for 2024 are adjusted by two-thirds of the positive inflation rate, that is, increased by 6.6%. Thus, if in 2023 the income limit for personal income tax purposes was up to 11,693 € for a rate of 0%, then in 2024 it will increase to 12,465 €. The resolution also adjusts the amounts of deductions, tax credits and...

Visa and Currencycleud have launched Visa Cross-Border Solutions, which provides cross-border money movement solutions for banks, fintech companies, currency brokers and other payment institutions. Source:https://www.electronicpaymentsinternational.com/news/visa-inc-and-currencycloud-launch-visa-cross-border-solution/?cf-view Visa Cross-Border Solutions combines proprietary cross-border and cash management capabilities with the solutions resulting from the acquisition of Currencycleud. Visa Cross-Border Solutions operates on a B2B4X model, meaning the company serves other businesses but focuses on improving the end-user experience. Visa Cross-Border Solutions offers a set of modular building blocks that can be easily integrated with a company's existing technology infrastructure. This is done through an application programming interface or API. These building blocks provide a range of capabilities including accepting payments in multiple currencies, foreign exchange (FX) with constant real-time rates, multi-currency wallets that store more than 30 currencies. This currency can be spent and sent to over 180 countries and territories. “Cross-border collaboration offers...

The FRA has issued several recommendations to EU and national authorities regarding access to rights for persons holding long-term EU resident status. Source:https://www.schengenvisainfo.com/news/agency-for-fundamental-rights-urges-eu-to-simplify-rules-for-obtaining-long-term-residency-status/ The agency believes that the EU should make long-term status more attractive to applicants, which can be done by simplifying application rules and issuing appropriate guidance. мTo apply for an EU long-term permit, migrants must prove continuous residence in an EU member state for five years and a stable income, which is a common problem for many applicants. Migrants often find it difficult to provide proof of residence and also find it difficult to meet the high language requirements for applicants. FRA experts recommend relaxing residency and language requirements for status and making language training more accessible to those seeking long-term residency status. At the same time, it is noted that the EU should provide easier access to status for child applicants and improve mobility within the EU among long-term residents. Moreover, the same report attempts to find solutions...

“We call for the early implementation of the Crypto Asset Reporting Framework (CARF) and amendments to the CRS [Common Reporting Standard]. We request the Global Forum on Tax Transparency and Information Exchange to establish an appropriate and coordinated time frame for the commencement of information exchange among relevant jurisdictions,” reads the consensus declaration signed by G20 leaders. Under the proposed framework, countries would automatically exchange information on cryptocurrency transactions between jurisdictions annually, including transactions on unregulated crypto exchanges and wallet providers. Crypto transactions are already subject to new disclosure standards in many countries. In May, the European Union approved updated CARF compliance rules establishing procedures for the automatic exchange of information between European governments for tax purposes. According to the new rules, the transfer of digital assets must be accompanied by the name of the beneficiary, the address of the beneficiary's distributed registry, and the beneficiary's account...