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In Tax

United States: IRS tightens voluntary disclosure rules

by , and 7 Mins Read

The IRS recently announced changes to its Form 14457, “Voluntary Disclosure Practice Preclearance and Application,” which allows taxpayers to apply to the IRS in an attempt to limit criminal exposure by disclosing past noncompliance and paying past taxes, interest and penalties. The new form includes several revisions that demonstrate a stricter approach towards taxpayers wanting to voluntarily disclose past tax-related misconduct, including: an admission of willfulness, a more detailed narrative requirement, a shorter time to prepare documents, and mandatory full payment. Taxpayers should consult with counsel to examine any increased risks associated with filing the revised form.

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In Tax

International: OECD Inclusive Framework issues model competent authority agreement (MCAA) on Amount B

by and 4 Mins Read

On 26 September 2024, the OECD Inclusive Framework published a Model Competent Authority Agreement to assist jurisdictions that have implemented the simplified and streamlined approach under Amount B to provide tax certainty. The MCAA is mainly intended to be applied in relation to Covered Jurisdictions as defined in the 17 June 2024 guidance. However, the OECD notes that Inclusive Framework members may use the MCAA as a model for negotiations with jurisdictions that are not defined as Covered Jurisdictions. This workstream has remained pending since the release of the guidance reports in February and June 2024. Therefore, the MCAA brings Amount B one step further toward completion and political agreement, in light of the envisaged local implementation commencing in fiscal years beginning after 1 January 2025.

In ESG

Brazil: The legal framework for low carbon hydrogen

by , , and 7 Mins Read

On 2 August 2024, Bill No. 2308/2023, which establishes the legal framework for low-carbon hydrogen in Brazil, was approved with a partial veto. Numbered as Law 14948/2024, it has created the National Low-Carbon Hydrogen Policy, which will form part of the country’s National Energy Policy. The Law has also established the competence of the National Agency for Oil, Natural Gas and Biofuels to authorize, regulate and inspect activities in the low-carbon hydrogen value chain, and has created the Brazilian Hydrogen Certification System and the Special Incentive Regime for Low-Carbon Hydrogen Production, a tax regime designed to foster technological and industrial development, competitiveness and added value in national production chains.

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In Tax

United States: Proposed DPL rules create immediate risks for many CTB elections

by , and 3 Mins Read

The new disregarded payment loss rules could create material, adverse tax consequences for taxpayers that make check-the-box elections for foreign disregarded entities within a US consolidated group (or otherwise form new foreign disregarded entities). As a result, taxpayers should assess their exposure under the disregarded payment loss rules before making any such elections or forming such entities within the US consolidated group.

In Tax

Global:  Ultimate beneficial ownership – Transparency rules in Canada, the UK and EU (Video chat)

by , and 1 Min Read

Registers of ultimate beneficial ownerships (UBO) are gaining momentum globally, with over 100 countries committed to implementing reforms to UBO regulations.
UBO disclosure and reporting requirements are important for businesses to be familiar with. For employers, understanding their own ownership structure and the transparency rules can mitigate compliance risks and also demonstrate commitment to ethical business conduct.

In Tax

Thailand: Increased tax exemption for severance pay now effective

by , , , and 1 Min Read

The personal income tax exemption amount on severance pay for terminated employees is now increased, following the publishing of the relevant Ministerial Regulations in the Royal Gazette. On 26 June 2024, the Ministerial Regulations, Volume 394 (B.E. 2567), (2024) under the Revenue Code Regarding Revenue Tax Exemption (“Ministerial Regulation”) was published in the Royal Gazette on 17 July 2024 and has already entered into force from that date. As a result, the personal income tax exemption amount on severance pay for terminated employees is now increased to the employee’s last 400 days’ wages or THB 600,000, whichever is less.

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In Tax

Germany: New tax audit focus – Application of Royalty Barrier Rule to Foreign-Derived Intangible Income (FDII)

by , and 5 Mins Read

Does your group have a German subsidiary or a German branch that pays royalties to a related party abroad under an intra-group license agreement? If so, a recent development in the German tax landscape could significantly affect you: The German Royalty Barrier Rule (RBR, Section 4j of the German Income Tax Act, (ITA)) is increasingly becoming relevant in German tax audits. Importantly, the German Tax Authorities (GTA) recently began expanding their scrutiny beyond traditional Patent/IP Box regimes.

In Anti-Corruption

Malaysia: Extension of time for lodgement of beneficial ownership information

by and 2 Mins Read

The implementation of the beneficial ownership reporting obligations, administered by the Companies Commission of Malaysia (“CCM”), came into effect on 1 April 2024. These statutory and reporting requirements imposed the obligation on companies to notify the CCM of their beneficial owners via the dedicated e-BOS portal. The CCM provided a transition period of three months (from 1 April 2024 to 30 June 2024) for companies to complete this reporting obligation.

In Tax

Canada: Changes to taxation of stock options and capital gains – Effective immediately

by , , , , , , , , , , , and 7 Mins Read

Changes to the capital gains inclusion rate and the employee stock option deduction rate (as proposed in Budget 2024) will apply to stock options exercised and shares sold on or after 25 June 2024. The new measure reduces the stock option deduction and capital gains tax exemption from 1/2 of the taxable amount to 1/3 of the taxable amount, if an individual’s annual combined limit of CAD 250,000 has been exceeded. The individual taxpayer can choose how to allocate the preferential tax treatment between the stock option income and capital gains to the extent the combined limit has been exceeded.

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