France unveils a new tax regime for management packages: a long-awaited clarification
France’s 2025 Finance Bill introduces a new legal framework, codified under Article 163 bis H of the French General Tax Code, applicable from 15 February 2025. This reform aims to provide clarity by creating a dedicated regime for gains realised on securities acquired or granted in consideration for salaried or management functions (whether by the issuing company, its subsidiaries or the parent entity).
Released on Apr 24, 2025
An overview of Portugal’s new IFICI regime
Following the end of the non-habitual residents (NHR) regime, Portugal has a new tax incentive regime for new residents, which aims to maintain competitiveness in terms of attracting foreign investment and skilled labour by establishing a more favourable tax regime for new residents who meet certain legal requirements.
Released on Apr 24, 2025
France’s Finance Bill for 2025: management package tax reform
The 2025 Finance Bill introduces a new tax regime for management package gains, in continuity with the Conseil d’Etat’s (French Supreme Administrative Court’s) 2021 framework. Gains realised by employees or corporate officers on securities, in connection with their functions, can benefit from the 30 per cent flat tax regime applicable to capital gains within the limit of a ratio equal to three times the equity multiple of the company. The portion exceeding this cap is taxed as salary. The reform clarifies the relevant tax and social security rules, offers greater legal certainty and revives underused instruments, such as preferred shares. Some uncertainties remain, pending further guidance expected from the French tax authorities in May 2025.
Released on Apr 22, 2025
International business reorganisations: tax neutrality and the preservation of Chilean taxing rights under Law 21,713
This article analyses Chile’s Law 21,713, which introduces a specific statute for international business reorganisations. It focuses on three requirements for tax neutrality, namely the production of effects in Chile, the preservation of Chile’s taxing rights and a legitimate business purpose, highlighting new interpretative challenges that could impact the practical application of the new statute.
Released on Apr 22, 2025
Japan considers next steps for VAT on cross-border e-commerce
Japan has finally started to make tangible progress in regard to reforming its value-added tax (VAT) framework to address the challenges brought about by the rapid expansion of cross-border e-commerce. Ongoing discussions are focused in particular on expanding the platform taxation regime to cover the cross-border sale of goods facilitated by online platforms offering fulfilment services, as well as on revising the de minimis import VAT exemption for low-value imported goods.
Released on Apr 22, 2025
Taxing intellectual property for multinationals in Australia: international misalignment?
The Australian Taxation Office (ATO) continues to pay close attention to the taxation of software arrangements. Its views have the potential to cause international misalignment on the way that certain cross-border payments are treated for taxation purposes. This article discusses the ATO’s guidance and a number of developing landmark Australian tax cases covering what constitutes a ‘royalty’.
Released on Apr 13, 2025
Price points and pressure points: multinationals’ transfer pricing in practice during a time of uncertainty
Historically, multinational companies have made operational decisions based primarily on strategic and commercial objectives, with tax professionals later reviewing and refining the resulting structures to ensure tax efficiency. But as major economies, including the US, introduce tariffs and other trade measures, transfer pricing is taking on a more prominent role in shaping business decisions. Although it may not be the central factor, it is becoming an influential consideration in corporate strategy, particularly in regard to a shifting geopolitical landscape.
Released on Apr 13, 2025
Duties and deductions in Canada and the US: the taxing truth about tariffs
The era of tariff-free global trade has long enabled supply chains to operate with stability and predictability. While pricing, supplier selection and customer relationships have always been influenced by various factors, the absence of tariff-related friction established a status quo; one that is now undergoing significant disruption. Another critical factor to evaluate for all Canadian taxpayers impacted by tariffs is their deductibility and the legal grounds based on which such deductions may be claimed.
Released on Apr 13, 2025
Company tax liabilities on ceasing operations in Ethiopia
The notion of taxing a taxpayer when they end their residential status in a country has been an issue for debate among scholars. Countries view the main risk associated with such withdrawal from the jurisdiction as the erosion or complete disappearance of the tax base. Tax is levied in such circumstances in order to provide the relevant tax authority with an opportunity to secure income tax from the departing individual without having to deal with the instant realisation of tax gains or losses. However, the Ethiopian principle in regard to an exit tax is focused on a perceivable gain obtained by the taxpayer upon ceasing residency in the country, which often comes with the disposal of investment assets through a sale or transfer.
Released on Mar 3, 2025
Navigating the intricacies of tax residency in Zambia for corporate entities
This article examines the intricacies surrounding the concept of a ‘place of effective management’ in determining tax residency for foreign corporate entities in Zambia. While Zambia’s Income Tax Act incorporated the concept of a ‘place of effective management’ to align with international practice, the undefined concept creates uncertainty that leaves the concept open to various interpretations. This article further critiques the inadequacy of the guidance provided by Zambia’s tax authority on the concept and compares the concept of a place of effective management with the alternative concept of a ‘head or main office’ in achieving certainty in the determination of the tax residence of corporate bodies.
Released on Jan 8, 2025
International mobility in the United Republic of Tanzania
This article provides a high-level overview of the taxation landscape for entities seeking to establish their business or invest in the United Republic of Tanzania. The current landscape provides for taxes payable or which entities are liable to collect and remit to the tax authorities in the United Republic of Tanzania. The article also discusses the potential tax consequences should an entity seek to exit the country. In this regard, the article examines both voluntary and compulsory exit situations.
Released on Jan 8, 2025
Navigating the UAE’s new corporate tax landscape: key considerations for businesses
The United Arab Emirates (UAE) has historically been known as a tax-friendly jurisdiction, attracting multinational corporations, family offices, investors and individuals to the country. However, in response to evolving global tax policies and a strategic shift away from the reliance on hydrocarbon revenues, the UAE has undertaken significant tax reforms, including the introduction of corporate tax at the federal level in 2023. This article explores the UAE’s evolving corporate tax environment, examining key corporate tax considerations and recent developments that impact businesses operating within the UAE.
Released on Jan 8, 2025
Taxing times ahead: what foreign investors need to know about Bahrain’s tax reform
The Kingdom of Bahrain is undergoing a significant economic transformation as it moves away from its historical reliance on oil and gas reserves. In this respect, Bahrain has strategically diversified its economy, emerging as a prominent business hub within the Gulf Cooperation Council (GCC). This transformation is marked by recent tax reforms, including the introduction of value-added tax (VAT) and a domestic minimum top-up tax, reflecting Bahrain’s aim to establish its long-term economic stability. This article examines the tax environment in Bahrain and the implications for businesses aiming to establish or expand their presence in Bahrain.
Released on Jan 8, 2025
Corporate global mobility: flips by Israeli tech companies
One of the current trends within the Israeli tech startup environment is that startups are increasingly considering restructuring their corporate structures by placing a non-Israeli company at the top of their holding structure, often referred to as a ‘flip’. While this can involve various non-Israeli jurisdictions, it is particularly common for the resulting parent company to be based in the US. The reasons behind this trend include tax incentives, investor preferences and regulatory advantages. The typical process of a flip involves the transfer of rights by rightsholders in the Israeli company to a newly formed foreign parent company, often creating immediate tax implications for Israeli stakeholders. However, the Israel Tax Authority has the ability to offer a favourable tax decision in this regard that can exempt Israeli rightsholders from tax, provided certain conditions are met. This decision by the regulator may also have a potential impact on the company’s future exit strategies and tax obligations. The implications of flips should, therefore, be carefully considered by startups and investors.
Released on Jan 8, 2025
Kenya’s tax framework and international mobility
Kenya, an East African country, was recently ranked the top African country for expatriates and ninth in the world in this regard. As businesses and people move to Kenya, it is crucial that they understand Kenya’s tax landscape, including the applicable tax laws and incentives meant to attract investors. This article provides a general overview of the local taxation rules, some of the incentives and the key consequences for businesses and individuals moving to or from Kenya.
Released on Jan 8, 2025
Foreign investment in Oman
Oman, a Gulf nation, has emerged as an attractive destination for foreign investment. With a stable political and economic environment, coupled with favourable government policies and incentives, Oman offers significant opportunities for businesses. The government’s pro-business initiatives, including tax exemptions and incentives, have further enhanced Oman’s appeal. While corporate income tax is levied at a moderate rate, the absence of personal income tax and the recent suspension of withholding tax on dividends and interest make Oman an even more attractive proposition. Additionally, the country’s robust infrastructure, the ease of doing business, and the growing focus on diversification contribute to the overall investment climate.
Released on Jan 8, 2025
Taxation and the latest tax-related developments in Mauritius
This article provides an overview of the provisions relevant to taxation in Mauritius and discusses key recent developments in this area.
Released on Jan 8, 2025
The taxation of income in Iraq: the current approach and what to expect
This article is intended for the attention of businesses planning to expand their activities in Iraq, as it describes the current legal framework regarding the taxation of income, be it generated by a local corporation, a foreign investor or an individual. The article discusses the applicable provisions and provides insight into the current and expected approach of the local tax authorities.
Released on Jan 8, 2025
France’s draft Finance Bill for 2025 - balancing fiscal justice and economic growth
As France faces significant economic challenges characterised by mounting public debt and a record-high deficit, the draft Finance Bill for 2025 is currently being discussed before the French Parliament. The Bill seeks to reduce the public deficit from seven per cent to five per cent of gross domestic product through a €19bn revenue increase, introducing new taxes targeted at high-income individuals and large corporations. The legislative process is complicated by a hung parliament and social crises. Despite the government’s efforts to address all the issues at stake, ongoing political instability raises questions about the efficacy and stability of France’s economic policies.
Released on Nov 25, 2024
New tax developments in Turkey 2024
Various changes were made to the Turkish tax system via Act No 7524, which was published in the Official Gazette on 2 August 2024. This article describes some of the important changes resulting from the Act.
Released on Nov 22, 2024
The incentive regime for large investments in Argentina - an overview
This article provides an overview of the Incentive Regime for Large Investments (RIGI) established by Law 27742 in Argentina, which offers a comprehensive framework of tax, customs and foreign exchange incentives aimed at promoting significant investments in key business sectors. This article explores the main features, eligibility requirements and benefits of the RIGI, highlighting its potential to attract substantial foreign and domestic investments in Argentina.
Released on Nov 21, 2024
Value-added tax on digital services in Peru
Legislative Decree No 1623, enacted on 4 August 2024, has introduced significant changes to Peru’s framework on value-added tax, extending its application to digital services and intangible goods acquired by Peruvian consumers from foreign providers. This reform addresses the expanding digital economy, imposing new tax obligations on non-resident providers and payment intermediaries, particularly financial institutions.
Released on Nov 18, 2024
Draft Italian Budget 2025 broadens the scope of the Italian digital service tax
Italy’s digital services tax could undergo its most significant transformation since its introduction in 2020. Initially conceived as a tax targeted at large multinational technology companies, the 2025 Draft Italian Budget drastically broadens the tax's scope, extending its application to resident and non-resident digital enterprises irrespective of their revenue.
Released on Nov 13, 2024
Practical guide on the preferential tax regimes available for individuals moving their tax residency to Greece
Since the end of 2019, Greece has been on list of countries that have enacted favourable tax regimes, designed to attract individuals to move their tax residence to the country. These regimes are the non-dom tax regime, the foreign pensioner’s tax regime and the employee and self-employed regime, known as 5A, 5B and 5C regimes, respectively, as per the corresponding articles in the Income Tax Code, which introduced them. This article provides an overview of the most important features of each of these tax regimes, considering the most recent amendments and administrative interpretations since their enactment.
Released on Nov 13, 2024
The Australian Tax Office’s unique approach to profit attribution and the implications for permanent establishments in Australia
In the view of the authors, the Australian Taxation Office (ATO) persists in adopting a method for attributing profits to permanent establishments (PEs) that is misaligned with international standards. This divergence may result in foreign taxpayers encountering a tax burden in Australia that is considerably more substantial than they might have anticipated. In this article, we examine the ATO’s methodology and explain why it can often culminate in an unusually high tax imposition on PEs within Australia.
Released on Nov 13, 2024
Chile VAT: new regulations for business to consumer sales transactions on digital marketplaces
As a measure to tackle the informal economy and tax evasion and to promote fair trade, Law No 21,713 on Compliance with Tax Obligations, enacted on 25 October 2024, incorporates relevant changes on the tax treatment applicable to the international business to consumer digital trade of goods. As a result, the responsibility for value-added tax collection on imports of low-value goods is shifted from customs authorities to the digital intermediation platforms facilitating such transactions. The specifics of these new regulations are set out in this article.
Released on Nov 13, 2024
Beacons of light in the gloomy withholding tax situation in Poland
This article discusses the current situation in regard to withholding tax in Poland and recent precedent-setting judgments by the administrative courts regarding the exemption of Luxembourg reserved alternative investment funds from withholding tax in Poland.
Released on Nov 13, 2024
The draft Finance Bill 2025: France adapts its merger tax regime to recent EU-driven corporate law reforms
The draft Finance Bill for 2025 was released on 11 October 2024 and is due to be examined by Members of the French Parliament from 21 October 2024. The merger tax regime for corporate restructurings is to be adapted (Article 17 of the draft Finance Bill) following the Ordinance 2023-393 of 24 May 2023 and Decree No 2023-430 of 2 June 2023, which transposed EU Directive 2019/2121 and reformed the legal regime in regard to company law. This article examines these developments.
Released on Nov 13, 2024
Brazil’s path to decarbonisation: tax incentives and policies on hydrogen and biofuels
Brazil is taking significant steps towards becoming a leading country in projects related to the energy transition. The second half of 2024 saw the enactment of important laws on hydrogen and biofuels/green fuels, which delivers a clear message: Brazil is committed to playing a key role in the energy transition.
Released on Nov 13, 2024
Privilege, penalties and good faith across jurisdictions
The focus of this conference panel discussion was privilege, penalties and good faith across jurisdictions. The panel discussed a hypothetical tax enforcement lifecycle, client–attorney privilege protection, the interaction between civil and criminal law proceedings, as well as document retention rules.
Released on Aug 26, 2024