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In an effort to address economic inequality, the Biden Administration has put forth bold proposals aiming to tax the wealthiest Americans more effectively.
Highlighted in President Biden’s State of the Union Address, these proposals include a minimum tax on the ultra-wealthy, specifically targeting those with assets over $100 million.
This initiative forms part of a broader strategy to generate over $4.5 trillion in new taxes over the next decade, with a significant portion coming from corporations.
The new tax proposals mark a significant shift in how wealth is taxed in the United States.
For the first time, a 25% tax could be imposed not only on annual income but also on the increase in the value of holdings, such as stocks and real estate.
This approach aims to capture the unrealized gains of the ultra-wealthy, a wealth source traditionally elusive to the IRS.
Despite the innovative nature of these proposals, many tax experts (this one included!) express skepticism regarding their enforceability.
Concerns revolve around the IRS’s ability to accurately assess the net worth and complex assets of the ultra-wealthy.
Additionally, the volatility of assets like stocks raises questions about the stability of this revenue source.
Critics argue that simpler changes to the tax code could achieve similar goals without the complexities of estimating unrealised gains.
The Biden Administration’s proposals resonate with global trends toward more equitable taxation.
Following a historic agreement on a minimum tax rate for multinational corporations, international finance ministers have begun discussions on a minimum personal tax for the world’s billionaires.
This reflects a growing consensus on the need for tax systems that more effectively target the wealth of the ultra-rich.
Efforts to increase taxation on the wealthy are not new.
Past administrations, including Obama’s, have sought to implement measures like the “Buffett rule” without success.
Today, despite strong Democratic support for taxing the ultra-wealthy, opposition from Republicans and some centrist Democrats remains a significant barrier.
The ongoing debate reflects a broader conversation about economic equity and the role of taxation in achieving it.
As these tax proposals move through the legislative process, they promise to ignite vigorous debates on fairness, economic policy, and the future of taxation in America.
While the path to implementation may be fraught with challenges, the Biden Administration’s initiative underscores a commitment to addressing wealth inequality and ensuring that all Americans contribute their fair share to the nation’s fiscal health.
Whether these proposals are remotely workable, is a different matter.
If you have any queries about this article Biden Seeks New Taxes on the Ultra-Wealthy or US tax matters in general, then please get in touch.
In this article, we consider some of the developments in the off-ing for Kazakhstan slated for 2024.
The dawn of 2024 brings new regulations for the digital mining sector, transitioning from a notification-based system to a structured licensing regime.
This change not only aims to formalize digital mining activities but also introduces specific requirements for digital miners, including the establishment of an automated system for commercial metering of electrical energy and telecommunications systems.
Kazakhstan marks 2024 with the termination of the business inspections moratorium that had been in place since 1 January 2020.
This moratorium, originally designed to shield small and micro-businesses from unscheduled state inspections, is giving way to a new era of regulatory oversight.
The government plans to introduce an innovative automated control system to halve the frequency of on-site inspections, a move articulated by Minister of National Economy Askar Kuantyrov as a significant shift towards minimizing state intervention and reducing penalties for businesses.
With this system, inspections are slated only for entities presenting an elevated risk, as indicated by the system’s assessments.
2024 also welcomes the third stage of the universal revenue declaration, compelling leaders and founders of legal entities, alongside individual entrepreneurs and their spouses, to submit a comprehensive Declaration of Assets and Liabilities.
This progression from the initial stages introduced in 2021 underscores Kazakhstan’s commitment to enhancing transparency and fiscal accountability among its business and public service sectors.
Significant amendments to the laws governing oil, gas, and subsoil use took effect on January 1, 2024.
These amendments seek to modernize the industry’s practices by updating the rules for metering crude oil and gas condensate and introducing a sophisticated information system for the accounting of crude oil, gas condensate, and processing products.
Starting January 1, 2024, Kazakhstan has refined its currency control measures to bolster oversight on foreign exchange transactions.
This includes the introduction of a new procedure for the repatriation of national and/or foreign currency for export or import, aimed at ensuring adherence to regulations and facilitating accurate and compliant foreign exchange activities.
Highlighting Kazakhstan’s dedication to sustainable energy development, the government ratified an agreement with the United Arab Emirates for the implementation of wind power station projects.
This agreement not only symbolizes international cooperation in the fight against global warming but also sets the stage for the development of significant renewable energy projects in Kazakhstan.
The Ministry of Agriculture has implemented reforms to the procedures for selling land plots at electronic auctions, facilitating a more transparent and efficient process.
These reforms include the formation of land plot lists for auctions and the submission of self-prepared proposals for vacant land plots suitable for auction.
These regulatory changes and initiatives represent Kazakhstan’s strategic approach to fostering economic growth, enhancing regulatory compliance, and advancing sustainable development.
As the nation embarks on these new paths, businesses and stakeholders are encouraged to adapt and align with the evolving regulatory landscape to leverage opportunities and navigate potential challenges effectively.
If you have any queries about this article on the Developments in Kazakhstan for 2024, or tax matters in Kazakhstan, then please get in touch.
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Portugal, known for its favorable taxation policies on cryptocurrency and its inviting climate, has recently shifted from a period of minimal taxation to introducing more structured tax guidelines in 2023.
This transition emphasizes the importance of understanding the new tax regulations for both residents and potential investors in the digital asset space.
The following tax Categories exist for Crypto Assets:
Crypto assets held for more than 365 days benefit from a tax exemption on any gains realized upon their sale.
Any gains from crypto assets held for less than a year are subject to a 28% capital gains tax. Similarly, income from passive crypto investments, like staking or airdrops, also attracts a 28% tax rate.
For individuals engaged in professional crypto trading, taxation varies.
Factors such as the frequency of trades, use of platforms, and the income’s proportion to other earnings play a critical role in determining tax rates, which can range from 14.5% to 53%.
Confirm your tax residency status and understand the implications of your asset holding periods.
Keep meticulous records of all crypto transactions to ensure accurate tax reporting.
Considering the complexities, seeking advice from tax professionals is recommended for staying compliant and optimizing tax liabilities.
Transactions involving gifts or inheritance of crypto assets are subject to a 10% stamp duty, with commissions attracting a 4% duty.
Portugal now allows real estate purchases directly with cryptocurrencies, following regulatory adjustments in notarial practices. These transactions require adherence to specific compliance measures.
The regulatory landscape for crypto taxation in Portugal is evolving.
Investors and residents should stay informed about the latest changes to ensure compliance and make informed decisions regarding their digital asset investments.
Partnering with a reputable advisory firm can provide valuable guidance and updates on the ever-changing tax environment.
As Portugal continues to refine its approach to crypto taxation, understanding the nuances of the current regulations is crucial for investors and residents alike.
By keeping detailed records, confirming one’s tax residency, and seeking professional advice, individuals can navigate Portugal’s crypto tax maze with confidence, ensuring compliance and optimizing their tax strategy in this dynamic market.
Final thoughts
If you have any queries about this article on Portugal’s crypto tax rules, or tax matters in Portugal more generally, then please get in touch.
In a significant move to adjust its tax framework, the Finance Act 2023 introduced an amendment that impacts non-residents receiving royalty and fees for technical services (FTS) in India.
Since its inception in 1974, the Income Tax Act 1961 has undergone numerous revisions, with the latest changes set to influence multinational corporations and their operations within India.
Previously, the tax rate for royalty and FTS received by non-residents was set at 10% (plus applicable surcharge and cess), as outlined in Section 115A of the Act.
This rate was momentarily increased to 25% in 2013 before being restored to 10% in 2015.
However, the Finance Act 2023 has now doubled this rate to 20% (plus surcharge and cess), effective from 1 April 2023.
The increase in the tax rate to 20% presents a significant shift for non-residents deriving income from royalty and FTS in India.
Given that many tax treaties with countries such as the United Kingdom, Canada, and the United States offer a lower tax rate of 15%, non-residents had previously opted for taxation under Section 115A of the Act due to its beneficial provisions, including specific exemptions from filing tax returns in India under certain conditions.
With the amendment, non-residents are likely to pivot towards claiming benefits under applicable tax treaties, which, while potentially offering lower tax rates, also necessitate additional compliance measures, including tax registrations in India and filing of income tax returns.
The requirement to file tax returns in India, necessitated by claiming treaty benefits, introduces a new layer of compliance for non-residents.
This includes the need for obtaining tax registrations and electronically filing Form 10F, a declaration form used by non-residents to claim treaty benefits.
Although there has been a temporary relief allowing manual submission of Form 10F until 30 September 2023, electronic filing will become mandatory thereafter, adding to the compliance burden for non-residents without a tax registration number.
Moreover, Indian payers making royalty or FTS payments to non-residents must now ensure that they collect and maintain specific documents from the non-residents to apply the treaty rates of withholding tax.
These documents include the Tax Residency Certificate, No Permanent Establishment Declaration, and the electronically filed Form 10F.
Failure to comply with these documentation requirements may result in withholding tax being applied at the higher domestic rate, along with potential penalties for the Indian payer.
The amendment could also have financial implications for Indian payers, especially in cases where royalty or FTS payments are grossed-up to cover the tax liability of the non-resident recipient.
The increased tax rate may lead to higher cash outflows for Indian payers, emphasizing the importance of efficient tax planning and compliance.
The Finance Act 2023’s decision to double the tax rate on royalty and FTS for non-residents marks an important change in India’s tax regime, aiming to align with global taxation practices.
While this may increase the tax burden and compliance requirements for non-residents, leveraging tax treaty benefits could mitigate some of these challenges.
As India continues to refine its tax laws, it is crucial for non-residents and Indian payers alike to stay informed and compliant with the evolving legal landscape.
If you have any thoughts on this article then please get in touch.
Angola’s legislative body has taken significant steps to refine its tax framework, enacting Law no. 14/23 on 28 December, which revises the VAT Code, and Law no. 15/23, reintroducing the Special Contribution for Foreign Exchange Operations (CEOC).
These measures aim to optimize the VAT system, making it more adaptable, efficient, and equitable for both taxpayers and the Tax Administration, while also addressing specific foreign exchange transactions.
The newly amended VAT Code introduces several critical changes designed to alleviate the tax burden on certain goods and transactions, improve the refund process for taxpayers, and enhance compliance and administrative efficiency:
The general VAT rate remains at 14%, but new reduced rates have been incorporated, including 7% for the Simplified VAT Regime, 5% for the import and supply of widely consumed foodstuffs and agricultural inputs, and 1% for imports and supplies within the Special Regime applicable to Cabinda Province.
The threshold for VAT refund requests has been increased from AOA 299,992.00 to AOA 700,000.00, facilitating greater recovery of VAT credits for businesses.
The non-submission or late submission of VAT returns now incurs a penalty of AOA 600,00.00 per infringement, aiming to improve compliance rates.
Non-resident entities engaging in taxable activities in Angola can now register in the General Taxpayers Register without appointing a tax representative, subject to forthcoming regulatory conditions and obligations.
Banks are required to electronically report quarterly summaries of transactions processed through automatic payment terminals to the Tax Administration, enhancing transparency and oversight.
Alongside the VAT modifications, Law no. 15/23 reintroduces the CEOC, targeting transfers in foreign currency outside Angola.
This levy applies to transactions such as technical assistance, service provision, consultancy, management, or unilateral transactions, with rates set at 2.5% for individuals and 10% for legal entities.
Exemptions from the CEOC include payments for health and education expenses (if paid directly to the institutions’ bank accounts), transfers of dividends, and repayments of loan capital and associated interest.
The CEOC aims to regulate foreign exchange operations more tightly, ensuring a fair contribution from transactions impacting Angola’s financial reserves.
These legislative updates signify Angola’s commitment to refining its tax system to support economic growth, enhance tax compliance, and maintain a balanced approach to foreign exchange transactions.
Businesses operating within Angola, particularly those involved in importation, supply of goods, and cross-border transactions, will need to adjust to these changes to ensure compliance and optimize their tax positions.
Meanwhile, the reintroduction of the CEOC underscores the importance of careful planning for international payments and financial operations involving Angola.
If you have any queries on this article titled ‘Angola amends VAT System’, or any Angolan tax matters, then please get in touch.
Ghana has embarked on a comprehensive overhaul of its tax regime with a series of amendments aimed at fostering economic development, supporting local industries, and promoting environmental sustainability.
These changes, spanning from income tax adjustments to the introduction of an emissions levy, reflect the government’s commitment to creating a conducive environment for businesses and individuals alike.
An important change under the Income Tax, 2015 (Act 896) is the revision of the annual graduated tax scale for resident individuals.
The tax-free threshold has been elevated from GH¢4,824.00 to GH¢5,880.00, providing a slight relief to the tax burden on individuals and potentially increasing disposable income for households.
The amendments to the VAT Act are particularly notable for their emphasis on supporting local manufacturing and sustainable transportation solutions. Key highlights include:
Furthermore, the amendment has refined the scope of exempt supplies, notably excluding imported textbooks, exercise books, and non-life insurance from VAT exemptions.
The government has revisited the Stamp Duty Act, 2005 (Act 689), adjusting stamp duty rates upwards for various instruments, signifying a move to increase revenue from transactions involving legal documents.
In the area of excise duty, adjustments aim to harmonize the treatment of similar products and extend the duty’s coverage to include imported plastic packaging, reflecting an effort to address environmental concerns and promote local industries.
The Exemptions Act now includes provisions to exempt customs duties and taxes on fishing gear imported for agricultural purposes, pending certification by the minister responsible for Fisheries and Aquaculture Development.
This measure is designed to support the fishing industry, a vital sector for Ghana’s economy.
A groundbreaking introduction is the emissions levy, targeting sectors and activities contributing significantly to greenhouse gas emissions.
This levy is part of Ghana’s broader strategy to mitigate environmental impact and promote sustainability.
It applies to specified sectors and motor vehicle owners, with the rates varying according to the emissions’ carbon dioxide equivalent and the vehicle’s engine capacity.
These tax law amendments reflect Ghana’s strategic approach to addressing contemporary economic challenges, promoting sustainable development, and enhancing the competitiveness of local industries.
By incentivizing the adoption of environmentally friendly practices and providing tax relief in targeted areas, Ghana aims to stimulate growth, support local manufacturing, and encourage responsible environmental stewardship.
As these changes take effect, they are expected to have wide-ranging implications for businesses, individuals, and the economy at large, positioning Ghana for a more sustainable and prosperous future.
If you have any queries about this article titled Ghana Implements Significant Tax Law Amendments, or Ghana tax matters in general, then please get in touch.
In its 2024 budget, Zambia sets forth a series of tax measures designed to stimulate economic growth, enhance policy consistency, and ensure equitable development across various sectors.
With a projected growth increase from 4% in 2023 to 4.8% in 2024, and amid a backdrop of contained external debt and decreasing inflation, these reforms aim to unlock Zambia’s economic potential through both incentives and tightened tax administration.
A reduction in income tax by 20% for five years for investments in rural areas, applicable to all sectors except mining, encourages businesses to contribute to rural economic development.
Tax exemptions for up to 10 years for profits derived from the cotton value chain promote the agriculture sector’s diversification and competitiveness.
Immediate 100% tax write-offs for new equipment for both developers and investors in MFEZs aim to spur significant investment in these special economic zones.
Aligning with incentives for other crops, this measure encourages the production and processing of sorghum and millet, supporting agricultural diversification.
The law now acknowledges the final ruling date in disputes as the official date for assessment, ensuring fairness in transfer pricing adjustments.
Removing the six-year limit on assessing transfer pricing issues enhances the tax authority’s flexibility in managing complex audits.
This measure ensures that related-party transactions employing non-OECD methods meet the Commissioner’s standards, aligning Zambia with international best practices.
The redefinition of terms to match OECD standards demonstrates Zambia’s commitment to maintaining coherence with global tax norms.
The introduction of agents to manage royalty withholding aims to improve compliance among small-scale miners, ensuring a level playing field in the mining sector.
Harmonizing penalties across the mining sector, including artisanal and small-scale activities, deters tax evasion and fosters fair competition.
Enhancing the Commissioner General’s authority to request information from various professionals and regulators strengthens the tax administration’s capacity to enforce compliance.
By incentivizing investment in key sectors, adjusting direct tax measures for individuals and industries, and tightening tax administration, Zambia is poised to harness its full economic potential while ensuring fairness and transparency in its tax system.
If you have any queries about this article on Zambia’s 2024 tax reforms, or other related tax matters, then please get in touch.
In an ambitious stride towards enhancing self-reliance, Zimbabwe has unveiled a comprehensive set of tax measures for 2024 aimed at bolstering domestic resources.
This initiative reflects the nation’s commitment to unlocking the full potential of its development while diminishing its dependency on external funding sources.
The tax reforms introduced encompass a variety of sectors, each tailored to maximize revenue generation without stifling economic growth:
A levy of 0.02 cents per gram on beverages with added sugar, promoting healthier consumption while generating revenue.
A 1% tax on outbound payments made in foreign currency, leveraging transactions within the Reserve Bank of Zimbabwe (RBZ) auction or interbank market.
Implementing a 1% levy on the gross sales of specific minerals and quarry products, targeting lucrative sectors with minimal impact on production costs.
A modest hike from 24% to 25%, balancing the need for revenue with the importance of corporate investment.
A 1% tax on the value of residential properties exceeding USD 250,000, encouraging equitable wealth distribution.
Reduction of the VAT registration threshold and revision of VAT exemptions aim to broaden the tax base and ensure essential goods remain accessible.
A 20% tax on the transfer of mining titles, ensuring that the nation benefits from its natural resource wealth.
Aligning with global efforts to ensure multinational enterprises contribute fairly to local economies.
To support these measures, Zimbabwe’s tax administration system, under the Zimbabwe Revenue Authority (ZIMRA), will see significant enhancements.
These include expanded enforcement powers, stricter compliance mechanisms for manufacturers, and innovative approaches to incorporating the informal sector into the tax system.
Furthermore, the integration of customs and excise systems with financial institutions aims to streamline processes and reduce evasion.
Zimbabwe’s tax reforms for 2024 represent more than a fiscal adjustment; they signify a transformative shift towards sustainable development and self-sufficiency.
By tapping into domestic resources, the nation seeks to lessen its reliance on external financing, fostering a resilient economy poised for growth.
For businesses and individuals alike, these changes offer both challenges and opportunities.
Adapting to the new tax environment will require flexibility and innovation, but it also opens the door to participating in Zimbabwe’s journey towards a more self-reliant and prosperous future.
If you have any queries relating to Zimbabwe 2024 Tax Strategy, or tax matters in Zimbabwe generally, then please get in touch.
In the dying days of 2023, specifically on December 29th, Montenegro‘s National Assembly passed significant amendments to the Corporate Income Tax (CIT) Law.
This marks a key moment in the country’s tax legislation history.
These amendments, effective from January 1, 2024, are set to modernize Montenegro’s tax system, bringing it into closer alignment with European Union (EU) standards.
This move is particularly aimed at harmonizing with the EU Council’s Directive 2009/133/EC, a cornerstone directive that establishes a common system of taxation applicable to mergers, divisions, transfers of assets, and exchanges of shares involving companies from different EU member states.
It also covers the transfer of registered offices of companies within the EU. The application of these rules will be activated upon Montenegro’s accession to the EU.
The recent legislative overhaul goes beyond mere compliance with EU directives. It introduces a series of substantive changes to the CIT regime, reflecting Montenegro’s commitment to fostering a transparent, EU-compatible tax environment.
Here’s a breakdown of the key amendments and their implications for businesses:
The revised CIT Law specifies the calculation of the CIT base, incorporating profit before taxation, as reported in the balance sheet.
This calculation must now adhere strictly to International Accounting Standards (IAS) and International Financial Reporting Standards (IFRS). A significant addition is the treatment of accounting policy changes.
Any income or expense arising from such changes will be recognized in the tax period of correction and spread evenly over five tax periods.
Furthermore, the amendments clarify that income from the liquidation of other legal entities will be excluded from the CIT base, alongside refining the conditions for write-offs.
The amendments have introduced precise guidelines for determining the acquisition value of assets.
In a notable shift towards market transparency, the tax authorities are now empowered to adjust the sale price of assets to reflect market value in transactions between both related and unrelated parties.
This adjustment is mandatory if the sale price is below the market rate, ensuring fair market practices and preventing tax evasion.
A significant change is the expansion of the withholding tax’s scope, now encompassing a wider range of legal entities.
The definition of taxpayers subject to withholding tax has been broadened, with the new law also taxing the distribution of liquidation surplus.
Moreover, permanent establishments must now withhold tax on dividends, profits, and liquidation surplus, among other payments, marking a considerable extension of tax obligations.
The amendments have ushered in new amortization rates designed to reflect the current economic realities more accurately.
These include reduced rates for buildings, roads, bridges, and similar assets, now set at 2.5%, and adjustments in rates for other asset groups to ensure a more equitable depreciation schedule.
In an effort to streamline tax benefits, the amendments eliminate the subsidy for newly employed individuals from the CIT Law, as these incentives are already encapsulated within the Personal Income Tax Law.
These amendments represent Montenegro’s proactive steps towards integrating with the European tax framework, signaling its readiness for future EU membership.
By aligning its tax laws with EU standards, Montenegro not only enhances its business environment but also strengthens its commitment to international compliance and transparency.
For businesses operating within Montenegro, these changes necessitate a thorough review of tax planning and compliance strategies, ensuring alignment with the new legislative landscape. For further details, then please get in touch.
In a significant move, the Malaysian government, through the Finance (No. 2) Act 2023 and the Income Tax (Exemption) (No. 7) Order 2023, has deferred the commencement of capital gains tax on the disposal of shares in unlisted Malaysian companies to March 1, 2024.
This exemption is effective from 1 January 2024, to 29 February 2024.
The Exemption Order offers a temporary reprieve from capital gains tax.
It applies for companies, limited liability partnerships, trust bodies, and co-operative societies on profits gained from the disposal of unlisted Malaysian company shares within the specified period.
The shares must be disposed of between 1 January 2024, and 29 February 2024 to qualify for the exemption.
This order does not apply to disposals where gains are considered business income under the Income Tax Act 1967.
Following this order, the capital gains tax will commence on 1 March 2024, aligning with the original announcement in the Malaysian Budget 2024.
The imposition of capital gains tax on disposals of shares in controlled companies outside Malaysia (owning real property in Malaysia or shares in another controlled company) still commences on 1 January 2024.
Disposals from 1 January 2024, to 29 February 2024, are not subject to the Real Property Gains Tax Act 1976 or capital gains tax.
This strategic deferment allows a window for entities to plan and adjust to the impending tax changes.
Businesses and investors involved in the Malaysian market must be aware of these updates to optimise their tax strategies and compliance.
This deferment represents an important transitional period in Malaysia’s tax landscape, especially for stakeholders in unlisted companies.
It reflects the government’s efforts to streamline tax policies while considering the impact on businesses.
If you have any queries around this article on Malaysia Defers Capital Gains Tax or Malaysian tax matters in general, then please get in touch.