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    Singapore Increases Carbon Tax

    Singapore Increases Carbon Tax – Introduction

    Singapore’s recent decision to significantly increase its carbon tax from SGD 5 ($3.72) per metric ton of CO2 to SGD 25 underscores the nation’s firm commitment to combating climate change and advancing towards a carbon-neutral future.

    This policy shift is a clear indication that, without deliberate government action, corporate efforts alone are unlikely to suffice in making a meaningful impact on carbon emissions reduction.

    Funding Innovation, Sustainability and Technology

    This tax hike is envisioned not as a harsh imposition but as a strategic encouragement for businesses to explore and adopt innovative, sustainable practices and technologies.

    With the tax projected to escalate to SGD 50 per metric ton by 2030, the race towards green profitability, where environmental sustainability and economic gains converge, is on.

    The focus now shifts towards investing in renewable energy, enhancing operational efficiency, and implementing carbon capture, utilisation, and storage (CCUS) technologies.

    Despite the existence of various CCUS methods, integrating these technologies into current industrial frameworks remains a significant challenge.

    Singapore’s journey towards economic viability for these technologies involves not only fostering local innovations but also forming international collaborations for carbon sequestration, especially considering the nation’s limited space for onsite carbon storage.

    The Importance of Renewable Energy

    Renewable energy, another cornerstone of Singapore’s sustainability strategy, faces similar spatial constraints.

    Despite abundant sunlight, the scarcity of land limits large-scale solar panel installations.

    In response, Singapore is diversifying its renewable energy portfolio through regional investments and plans to import up to 4 gigawatts of renewable power, possibly including solar, wind, and hydroelectric sources, from neighboring countries.

    This approach, however, introduces new challenges, such as ensuring the consistent reliability of power supply and managing the complexities of subsea cable installations for energy transmission.

    Moreover, the intermittent nature of renewable energy sources necessitates innovative solutions, such as diverse sourcing and storage systems, to ensure a stable energy supply.

    International Challenges

    Navigating the path to carbon neutrality is further complicated by international policy ambiguities related to carbon trading and storage.

    Achieving a global consensus on these issues is crucial for facilitating a seamless transition to greener practices.

    Singapore Increases Carbon Tax – Conclusion

    As the world gradually shifts towards carbon pricing and sustainability, early adopters like Singapore are poised to emerge as more resilient and competitive entities.

    With a pragmatic yet ambitious approach, Singapore’s journey towards energy decarbonization offers valuable lessons and opportunities for innovation and collaboration on a global scale.

    Final thoughts

    If you have any queries about this article on Singapore Increases Carbon Tax, or any other Singopore tax matters, then please get in touch.

    New Zero Tax Rate on Photovoltaic Systems in Germany

    New Zero Tax Rate on Photovoltaic Systems in Germany – Introduction

    The world of taxation and renewable energy has seen a significant shift in Germany with the introduction of the zero VAT rate on photovoltaic systems, as per Section 12 (3) of the German Value Added Tax Act (UstG), effective from January 1, 2023.

    This groundbreaking move, aimed at promoting green energy, initially stirred confusion and uncertainty among stakeholders.

    However, the German Federal Ministry of Finance (BMF) has released comprehensive clarifications, most recently in its letter dated 30 November 2023, building on earlier guidance from February 27, 2023.

    Here’s an in-depth look at what these changes entail.

    Key Developments in the BMF’s November 2023 Circular

    Withdrawal Option for System Operators

    One of the critical aspects addressed is the option for withdrawal.

    This is particularly relevant for operators who installed their systems before 31 December 2022, and had opted out of the small business regulation to benefit from the input tax deduction.

    The BMF allows a retroactive withdrawal to 1 January 2023, but only until 11 January 2024, as a protection of legitimate expectations.

    Unified Supply of Photovoltaic and Storage Systems

    The BMF clarifies that a combined purchase of a photovoltaic system and an electricity storage system under a single contract is considered a unified supply of goods.

    This means the zero tax rate applies to the entire system, streamlining the VAT process for such transactions.

    Expanding the Scope of Zero-Rated Items

    The BMF has expanded the scope of zero-rated items to include solar carports and solar patio roofs, along with their direct mounts.

    This extension, however, doesn’t cover the entire substructure to which the panels are attached.

    Simplification for Electricity Storage Systems

    For simplification, electricity storage systems are preferentially treated under the zero tax rate if they have a capacity of at least 5 kWh.

    Storage systems using hydrogen as a medium are also included, provided the hydrogen is exclusively used for converting energy back to electricity.

    Additional Clarity on Related Measures

    The BMF’s guidance extends the zero tax rate to necessary modifications like the extension or renewal of the meter box due to the installation of the photovoltaic system.

    However, it doesn’t cover other electricity-consuming systems powered by the photovoltaic system, such as heat pumps or charging infrastructure.

    Invoice Identification for Small Businesses

    Small businesses exclusively operating a photovoltaic system and engaging in tax-free letting and leasing can use their market master data register number in invoices instead of the VAT identification number, easing administrative burdens.

    Implications and Takeaways

    This comprehensive guidance from the BMF is a significant step in clarifying the implementation of the zero VAT rate for photovoltaic systems in Germany.

    The circular ensures:

    New Zero Tax Rate on Photovoltaic Systems in Germany – Conclusion

    The BMF letter serves as a crucial supplement to its February 2023 counterpart, providing clarity and legal certainty in the application of the zero VAT rate for photovoltaic systems in Germany.

    This move not only streamlines tax processes for businesses but also significantly contributes to the promotion of renewable energy sources in the country.

     

    Final thoughts

    If you have any queries about this article on New Zero Tax Rate on Photovoltaic Systems in Germany, or German tax matters in general, then please get in touch.

     

    Exemption for Renewable Energy Projects

    Exemption for Renewable Energy Projects – Introduction

     

    In an impactful decision, the Spanish General Directorate of Taxes (SGDT) has clarified that capital gains exemptions will apply to the sale of shares in subsidiaries dedicated to photovoltaic energy projects, even if the construction has not commenced. 

     

    This announcement marks an essential step in providing clarity for the renewable energy sector.

     

    What Triggered This Decision?

     

    The ruling specifically pertains to holding companies engaged in renewable energy projects, focusing on photovoltaic energy. 

     

    The subsidiaries or Special Purpose Vehicles (SPVs) involved in these projects are at various stages, from land scouting to feasibility analysis and permits and licenses management. 

     

    However, these SPVs might not possess their own resources and personnel.

     

    Exemption Application

     

    The SGDT’s perspective is that these SPVs should not be considered mere asset-holding entities. 

     

    Instead, they are actively involved in the economic activity of promotion and development. 

     

    Provided that they have their organizational setup for production and distribution, the SGDT allows for the application of the exemption for capital gains derived from the sale of these SPVs, even before the actual construction work on the photovoltaic solar parks has started.

     

    Timing Matters

     

    The SGDT emphasizes that the income resulting from the sale of SPVs should be allocated to the corporate income tax in the year it accrues. 

     

    This applies to the fixed part of the agreed price. 

     

    For the variable part, dependent on uncertain future events, it should be included in the tax base when those events occur, and a reasonable estimate can be made of the variable price.

     

    Previous Rulings

     

    This ruling closes the debate that arose from previous similar cases.

     

    Some prior rulings questioned the exemption when economic activity had not yet materially commenced.

     

    However, recent rulings have taken a more favorable stance regarding the application of the exemption.

     

    Renewable Energy Sector

     

    This ruling provides much-needed clarity for businesses operating in the renewable energy sector, allowing for the application of capital gains exemptions on SPV sales. 

     

    It is essential to review the conditions and assess each case individually to ensure compliance.

     

    Transfer Pricing Considerations

     

    This decision also highlights the need to evaluate the valuation of services provided by holding companies and group entities to SPVs. 

     

    Such assessments should align with market value and necessitate a review of the group’s transfer pricing policy.

     

    If you have any queries about Spain’s Exemption for Renewable Energy Projects, or Spanish tax matters in general, then please get in touch.

    Finance Bill: Fueling Green Industry Investments with Tax Credits

    Introduction

     

    France’s vision for a greener and more sustainable future has taken a significant step forward with the release of the French Finance Bill for 2024, unveiled on 27 September 2023. 

     

    One of the headline features of this bill is the introduction of a Tax Credit for Investments in Green Industries, known as the Crédit d’impôt “Investissement Industries Vertes” (C3IV). 

     

    This tax credit is designed to reinvigorate the country’s industrial sector and reduce the carbon footprint of French industries, setting a promising course towards environmental sustainability.

     

    Investing in Green: The C3IV Tax Credit

     

    The C3IV tax credit is poised to make a substantial impact on the development of green industries in France. 

     

    It is available to companies based in France that make tangible and intangible investments in the production of specific green products, with a strong emphasis on sustainability and carbon reduction. 

     

    The eligible products encompass cutting-edge technologies that are vital for a greener future, including new-generation batteries and their key components, solar panels, wind turbines, and heat pumps.

     

    Key Highlights of the Tax Credit

     

    Eligible Investments

     

    Companies can claim the tax credit for tangible investments, which include land, buildings, facilities, equipment, and machinery, as well as intangible investments such as patent rights, licenses, knowledge, or other intellectual property rights.

     

    Varied Incentives

     

    The tax credit’s value varies, ranging from 20% to 60% of the investments made, depending on factors like the location of the investment and the size of the investing entity. 

     

    Importantly, this incentivizes both small and large companies to contribute to the green industry.

     

    Maximum Limit

     

    The tax credit comes with a maximum limit, which ranges from €150 million to €350 million, determined by the location of the investment. 

     

    This ensures that the benefits are distributed across various regions.

     

    Tax Application

     

    The tax credit is applied against the corporate income tax due by the company for the fiscal year in which the investments are made. 

     

    If the credit exceeds the tax liability, the excess will be reimbursed to the company.

     

    Economic Impact and Eligibility Criteria

     

    The C3IV tax credit is expected to not only boost environmental sustainability but also stimulate the French economy. 

     

    According to the French government, this initiative has the potential to generate approximately EUR 23 billion in investments and create around 40,000 jobs in France by 2030, showcasing the power of green industry growth.

     

    To be eligible for this tax credit, companies must align with certain criteria, subject to approval by the Ministry of Finance and authorization by the European Commission. 

     

    Eligible expenditures include:

     

     

    It’s important to note that the C3IV tax credit will apply to projects approved by the Ministry of Finance and subject to prior approval by the Agency for Ecological Transition (ADEME). 

     

    The eligibility window extends until December 31, 2025, with applications accepted from September 27, 2023, onward.

     

    Conclusion

     

    France’s 2024 Finance Bill and the introduction of the C3IV tax credit signify a resolute commitment to a sustainable and environmentally responsible future. 

     

    This innovative approach not only promotes the growth of green industries but also aims to strengthen the nation’s industrial base. 

     

    With the potential to drive billions in investments and create thousands of jobs, this tax credit is a bold step towards a cleaner, greener, and more prosperous France. 

     

    As the world grapples with environmental challenges, France’s vision for green investments sets a powerful example for the global community.

     

    If you have any queries about this article, or tax matters more generally, then please get in touch.

    The Netherlands’ Green Budget?

    Introduction

    In a bid to take substantial strides towards its climate goals, the Dutch government unveiled a series of legislative proposals and amendments concerning energy and environmental taxes on Budget Day.

    These measures are geared towards reducing the Netherlands’ greenhouse gas emissions by a commendable 55% by 2030, in alignment with the government’s climate ambitions.

    However, it’s essential to bear in mind that these proposals are subject to discussions, amendments, and adoption by the Dutch parliament.

    This article provides an in-depth look at some of those proposals covering:

    Corporate Income Tax

     

    From 1 January 2024, the energy investment deduction (EIA) rate will undergo a reduction, declining from 45.5% to 40%.

    Additionally, the sunset clause for energy and environmental deductions has been extended until 2028, implying that they will remain in effect, at least until that time.

     

    Energy Tax

     

    Energy tax exemption for metallurgical and mineralogical activities

    As of 1 January 2025, the energy tax exemption for electricity and gas used in metallurgical and mineralogical processes will be eliminated.

    The Dutch government views these exemptions as fossil subsidies, which no longer align with the nation’s climate objectives.

    New Specific Input Exemption for Hydrogen Production

    In addition, a new energy tax exemption will be introduced on 1 January 2025, for the supply of electricity used in hydrogen production via electrolysis.

    This exemption is confined to electricity utilized directly in the water-to-hydrogen conversion process, encompassing activities like demineralization, electrolysis, and the purification and compression of resulting hydrogen.

    Exemptions Related to Electricity Production

    Starting January 1, 2025, several changes are proposed regarding exemptions for electricity production, including cogeneration.

    Key changes include:

    Phase-Out of Special Energy Tax Rate for Greenhouse Horticulture Sector

    The reduced energy tax rate presently applicable to the greenhouse horticulture sector will be gradually phased out, commencing on 1 January 2025, and concluding in 2030.

    Changes to Energy Tax Brackets

    Effective from 1 January 2024, a new, lower bracket in the energy tax will be introduced for both electricity and gas.

    This bracket will cover the first 2,900 kWh of electricity and 1,000 m3 of gas.

    This adjustment is intended to provide the government with the flexibility to reduce energy tax for households when necessary, aligning with the current price cap for households.

    Amendments to Rules for Block Heating

    Various changes will be made to tax regulations for block heating, designed to accommodate the modifications in tax brackets mentioned above.

    Carbon Tax

    Increased Minimum Carbon Tax Price for Industrial and Electricity Generation Sector

    Starting January 1, 2024, the Dutch minimum carbon tax prices for the industrial and electricity generation sectors will rise. Despite these increases, the government anticipates no budgetary implications, given the existing EU ETS price. The new minimum prices are as follows:

    Introduction of a Carbon Tax for the Greenhouse Horticulture Sector

    Commencing January 1, 2025, a carbon tax will be introduced for CO2 emissions in the greenhouse horticulture sector, mirroring the current system in place for the industrial sector.

    This development coincides with the introduction of specific EU ETS obligations for the built environment.

    Coal Tax

    With effect from 1 January 2028, the coal tax exemptions for dual coal use and coal utilization for energy production will be discontinued.

    The current coal tax rate stands at EUR 16.47 per metric ton.

    Other proposals

    New information obligations will be incorporated into specific energy tax regulations to align with the European Commission’s guidelines on State Aid for climate, environmental protection, and energy.

    Commencing on 1 January 2024, these rules will encompass principles for providing data and information, upon request, to comply with EU obligations.

    Conclusion

    The Dutch government’s commitment to climate goals is evident in these proposed tax changes, which seek to incentivize eco-friendly practices while gradually phasing out less sustainable measures.

    These proposals will be closely monitored as they make their way through the legislative process, potentially reshaping the landscape of energy and environmental taxation in the Netherlands.

    If you have any queries about the Netherlands’ Green Budget, or Dutch tax in general, then please get in touch.

    Zero VAT Rate for Solar Panels in Irish Homes

    Introduction

    In a significant move towards promoting renewable energy and reducing carbon emissions, the Irish Department of Finance made an exciting announcement on April 5, 2023. 

    Starting from May 1, 2023, a zero rate of value-added tax (VAT) will be applied to the supply and installation of solar panels in private dwellings. 

    This change was made possible by amendments to the Principal VAT Directive through Council Directive (EU) 2022/542 on April 5, 2022. 

    The Irish Revenue Commissioners have also released detailed guidance to ensure transparency and clarity for homeowners and businesses regarding the application of the zero rate of VAT.

    Scope of Application

    The zero rate of VAT applies specifically to the supply and installation of solar panels on or adjacent to immovable goods, which in this case refers to private dwellings. 

    This allows flexibility in the placement of solar panels, whether they are installed directly onto the private dwelling (e.g., on the roof) or mounted on the ground beside it. 

    The definition of “private dwelling” includes a wide range of residential properties such as houses, apartments, duplexes, and even immobilized caravans and mobile homes. 

    Essentially, any private dwelling that can be effectively immobilized qualifies for the zero VAT rate on solar panels.

    Conditions for Zero VAT Rate

    To be eligible for the zero rate of VAT, both the supply of solar panels and their installation must be carried out by the same business within the same contract. 

    This requirement emphasizes the importance of engaging a qualified and experienced contractor who can provide end-to-end solutions for solar panel installation.

    Limitations on Moveable Goods

    It’s important to note that while the zero VAT rate encourages the adoption of solar panels in private dwellings, it does not extend to moveable goods such as boats or mobile homes. 

    The focus of this initiative is primarily on immovable residential properties, ensuring that the zero rate of VAT applies specifically to homes.

    Key Takeaway

    The introduction of a zero rate of VAT for solar panels in private dwellings is a significant step towards achieving sustainable and eco-friendly homes in Ireland. 

    By reducing installation costs, this measure aims to incentivize homeowners to embrace solar energy and contribute to the nation’s commitment to carbon reduction. 

    The zero rate of VAT encourages the adoption of renewable energy sources, fostering a greener future for both individuals and the environment.

    Conclusion

    The Irish government’s decision to implement a zero rate of VAT for the supply and installation of solar panels in private dwellings reflects their dedication to environmental sustainability and carbon reduction. 

    This initiative empowers homeowners to make a positive impact by transitioning to renewable energy sources and significantly lowering their carbon footprint. 

    With clear guidelines provided by the Irish Revenue Commissioners, homeowners can confidently explore solar panel installations and take advantage of the cost-saving benefits offered by the zero rate of VAT. 

    As countries worldwide strive for sustainability, the integration of solar energy in private dwellings will undoubtedly play a vital role in achieving a more eco-friendly society.

    If you have any queries about this article, or Irish tax matters more generally, then please do not hesitate to get in touch.

    The content of this article is provided for educational and information purposes only. It is not intended, and should not be construed, as tax or legal advice. We recommend you seek formal tax and legal advice before taking, or refraining from, any action based on the contents of this article

    Czech Windfall Profits Tax announced

    IntroductionCzech Windfall Profits Tax

    Last week, the Czech Republic’s Senate approved a proposed amendment in respect of a Windfall Profits Tax (WFT).

    Czech Windfall Profits TaxWhat is it?

    The WFT is based on the related Regulation of the Council of the European Union. However, the Czech Republic’s version differs from the European legislation in some key areas.

    Significantly, for the period in which the measure is engaged, it will introduce a 60% tax rate on ‘extraordinary profits’ as opposed to the 33% rate recommended by the EU.

    For those that meet the relevant conditions, this new 60% rate will apply for the period 2023 to 2025. This is on top of the standard corporate income tax (CIT) which is currently 19%.

    What are extraordinary profits?

    Extraordinary profits would be defined as the general income tax base exceeding the average of tax bases or tax losses for taxable periods beginning and ending between 1 January 2018 and 31 December 2021, plus 20%.

    This tax base would be subject to the 60% additional rate.

    The taxpayer will likely to be within the corporate income tax and generating income within the windfall profits tax of at least CZK 50 million in a taxable period falling at least partially within the “windfall profits tax application period” from 2023-2025.

    Taxpayers within the Czech Windfall Profits Tax

    General

    There are three categories of taxpayers subject to the windfall profits tax.

    We will look at each, in turn, below.

    Category one – special activities

    Firstly, taxpayers who have income from the ‘relevant activities’ that include:

    This is provided that the income qualifying for WFT from these activities for the first accounting period ending on or after 1 January 2021 accounted for at least 25% of their annual total net turnover. 

    Category two – general category

    Taxpayers generating income from the following activities:

    In the windfall profits tax application period the taxpayer is part of a corporate group. Here, they will be within its scope where the sum of the relevant income of all taxpayers within the group for the first accounting period ending on or after 1 January 2021 of at least CZK 2 billion.

    Alternatively, an entity records income qualifying for the windfall profits tax of at least CZK 2 billion for the first accounting period ending on or after 1 January 2021

    Category three – banks

    The income qualifying for the Windfall Profits Tax is net interest income.

    Where net interest income for the first accounting period ending on or after 1 January 2021 exceeds CZK 6 billion while meeting the general precondition of having generated net interest income for the relevant taxable period of at least CZK 50 million, then they are within the scope of WFT.

    When is the Czech Windfall profits tax paid?

    The first payments of WFT should be made in the latter half of 2023. These payments will be based on the estimated tax reported for the last taxable period ending before 1 January 2023.

    This report must include information they would have recorded in their windfall profits tax return and use this information to determine what payments are required.

    The report should be submitted by 3 July 2023 at the latest.

    If you have any queries about the Czech Windfall Profits Tax or Czech tax matters more generally, then please do not hesitate to get in touch.

    The content of this article is provided for educational and information purposes only. It is not intended, and should not be construed, as tax or legal advice. We recommend you seek formal tax and legal advice before taking, or refraining from, any action based on the contents of this article