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    UK’s R&D Tax Budget Growth Lags Behind OECD Counterparts

    R&D Tax – Introduction

    A recent report highlights that the United Kingdom’s growth in Research and Development (R&D) tax incentives is falling behind other OECD countries.

    This trend raises concerns about the UK’s ability to remain competitive in attracting innovation-driven businesses.

    Let’s explore the details of this issue and its potential implications for the UK’s economy.

    What Are R&D Tax Incentives?

    R&D tax incentives are government initiatives designed to encourage businesses to invest in research and development activities.

    These incentives often take the form of tax credits, deductions, or grants, reducing the financial burden of innovation.

    The UK has long been recognised for its generous R&D tax schemes, but recent findings suggest that its growth in funding these incentives has stagnated compared to other OECD nations.

    Why Is the UK Falling Behind?

    Several factors contribute to this trend:

    1. Policy Uncertainty: Frequent changes to credit schemes have created uncertainty for businesses, discouraging long-term investment in innovation.
    2. Focus on Cost Savings: The government has prioritised cost-saving measures, reducing the scope of R&D incentives for certain sectors.
    3. Global Competition: Other OECD countries, such as the United States, Canada, and Australia, have significantly expanded their R&D budgets, making them more attractive to innovation-focused companies.

    Implications for Businesses

    For UK businesses, the stagnation in R&D tax growth poses challenges:

    What Does This Mean for the UK Economy?

    Innovation is a key driver of economic growth, and R&D incentives play a crucial role in fostering it.

    If the UK fails to keep pace with other countries, it risks losing its competitive edge in sectors like technology, pharmaceuticals, and manufacturing.

    R&D Tax – Conclusion

    The UK’s declining R&D tax budget growth is a wake-up call for policymakers.

    To remain an innovation leader, the country must prioritise consistent, generous incentives that encourage businesses to invest in R&D.

    Final Thoughts

    If you have any queries about this article on incentives, or tax matters in the United Kingdom in general, then please get in touch.

    Alternatively, if you are a tax adviser in the UK and would be interested in sharing your knowledge and becoming a tax native, then there is more information on membership here.

    Film Tax Credits: California rolls out the red carpet

    Film tax credits – Introduction

    In sunny California, the state’s film tax credits are helping to secure its place as a leader in the film and television industry.

    On July 10, 2023, Governor Gavin Newsom signed a new law that extends and expands California’s Film and TV Tax Credit Program 3.0.

    Originally set to expire in June 2025, the program will now run until June 2030, under the new name “Program 4.0”.

    This program, which offers $330 million a year in tax credits, has already started attracting new productions to California.

    The Impact of Program 4.0

    With the launch of Program 4.0, California has become an even more appealing destination for film and television productions.

    Colleen Bell, the Director of the California Film Commission, noted that by mid-2024, the state had already welcomed 12 new TV series and one relocating series.

    One of the major projects drawn to California was “Suits: L.A.” by Universal Content Productions LLC, which was awarded a $12 million tax credit.

    The show’s shift from Canada to California is expected to inject $50.7 million into the state’s economy and create around 2,600 jobs.

    Why Film Tax Credits Matter

    California’s move to extend its film tax credits isn’t just about keeping the state’s film industry alive; it’s about ensuring its dominance in a competitive market.

    Since 2021, 17 other states have introduced or expanded their own film tax incentive programs. By supporting local productions, states can encourage economic growth, create jobs, and even boost tourism.

    California, recognising the growing competition, made significant changes in Program 4.0. The most notable change is that the tax credits are now refundable, which makes them more attractive to filmmakers.

    Additionally, the program aims to support people from underserved communities by requiring projects to submit diversity, equity, inclusion, and accessibility (DEIA) workplans.

    Projects must also show a commitment to hiring individuals who reflect the diversity of California’s population.

    A Boost for California’s Economy

    The film and television industry in California provides more than 700,000 jobs and generates nearly $70 billion in wages.

    It also brings in billions of dollars in production spending. This makes it clear why the state is so invested in keeping film productions in California.

    The tax credits aren’t just about supporting big-budget films; they’re a key part of the state’s economic strategy.

    In September 2024, the California Film Commission awarded $51.6 million in tax credits to 18 projects, including a film about singer Janis Joplin.

    Shailene Woodley, one of the producers and stars of the Janis Joplin biopic, expressed her gratitude to the California Film Commission, saying that California was the best place to capture Janis’s life story authentically.

    Film tax credits – Conclusion

    California’s Film and TV Tax Credit Program 4.0 has proven to be a valuable tool for keeping the state at the forefront of the entertainment industry.

    By offering generous, refundable tax credits and promoting diversity within productions, California is ensuring that it remains a top choice for filmmakers around the world.

    Final Thoughts

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

    Alternatively, if you are a tax adviser in the US. and would be interested in sharing your knowledge and becoming a tax native, then there is more information on membership here.

    Malaysian Tax Incentives & Forest City

    Malaysian Tax Incentives – Introduction

    On 20 September 2024, Malaysia’s Finance Minister II, Datuk Seri Amir Hamzah Azizan, unveiled an exciting new financial incentive package for the Forest City Special Financial Zone (FCSFZ).

    Forest City, often referred to as the ‘Jewel of the South’, is located on four reclaimed islands in the Straits of Johore, nestled between the State of Johore and Singapore.

    Recently declared a duty-free zone, Forest City aims to become a preferred regional financial hub, similar to Shenzhen in China and the Dubai International Financial Centre in the UAE.

    The New Tax Incentives

    General

    To support the development of FCSFZ, Malaysia’s Finance Minister announced a range of tax incentives that aim to attract businesses and skilled workers to the area.

    The goal is to make Forest City an attractive destination for international finance and innovation.

    Here are the key tax benefits outlined in the financial package:

    Corporate Tax Benefits

    Companies in FCSFZ will enjoy a concessionary corporate tax rate ranging between 0% and 5%.

    This makes the region highly competitive for businesses looking to reduce tax costs.

    Special Income Tax for Knowledge Workers

    Knowledge workers, as well as Malaysians working in the FCSFZ, will benefit from a special individual income tax rate of just 15%.

    This is intended to attract skilled professionals from various sectors.

    Single-Family Office Scheme

    Family offices, which manage the wealth of high-net-worth families, will enjoy a 0% tax rate for a period of 10 years under the Single-Family Office Scheme.

    Further details for this regime, targeted at high-net-worth investors, are as follows:

    This scheme will be coordinated by the Securities Commission Malaysia and is set to be operational in the first quarter of 2025.

    Global Business Services & Financial Technology

    Global business services, financial technology firms, and foreign payment system operators will be subject to a special tax rate of 5%.

    Incentives for Financial Institutions

    Qualifying banking institutions, insurance companies, and capital market intermediaries will receive incentives such as special deductions on relocation costs, enhanced industrial building allowances, and withholding tax exemptions.

    These benefits are designed to lower operational costs for financial sector entities moving into the FCSFZ.

    Flexibilities for Foreign Banks

    Locally incorporated foreign banks will be given regulatory flexibilities to establish additional branches within the FCSFZ.

    They will also have the ability to borrow in foreign currencies and invest in foreign currency assets.

    FCSFZ and the Johore-Singapore Special Economic Zone

    There is excitement surrounding the anticipated agreement between Malaysia and Singapore to establish the Johore-Singapore Special Economic Zone (JS-SEZ), with the deal expected to be signed in November 2024.

    It is hoped that the FCSFZ will complement, rather than compete with, the initiatives planned for JS-SEZ. Together, these zones are expected to stimulate economic activity in the region.

    Challenges and New Opportunities for Forest City

    Forest City has faced difficulties in recent years, particularly as Chinese investors, who were a key target for the development, have scaled back their overseas investments.

    This slowdown is due to economic challenges within China itself.

    However, by offering this new incentive package, Malaysia’s government hopes to broaden Forest City’s appeal, attracting a more diverse range of investors and giving the project a much-needed boost.

    Malaysian Tax Incentives – Conclusion

    The FCSFZ incentive package is an ambitious step by the Malaysian government to revitalise the Forest City development.

    By offering a competitive tax environment and regulatory flexibilities, it aims to attract global businesses and high-net-worth individuals, turning Forest City into a leading financial hub for the region.

    Final Thoughts

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

    Alternatively, if you are a tax adviser in Malaysia and would be interested in sharing your knowledge and becoming a tax native, there is more information on membership here.

    Singapore’s Tax Relief for Startups: A Boon for Entrepreneurs?

    Singapore’s Tax Relief for Startups – Introduction

    Singapore has become a global hub for startups and entrepreneurs due to its business-friendly environment, strategic location, and supportive tax policies.

    To further boost the growth of new businesses, Singapore offers several tax relief programs designed to help startups during their early years.

    These tax reliefs make it easier for entrepreneurs to focus on growing their businesses without worrying about excessive tax burdens.

    What Tax Relief Programs Are Available for Startups?

    Singapore has introduced several tax relief programs specifically aimed at newly incorporated companies. The two main tax relief schemes are:

    1. Startup Tax Exemption (SUTE): Under this scheme, qualifying new companies are exempt from tax on the first SGD 100,000 of their chargeable income for the first three years. This gives startups a significant financial advantage during the critical early years when they may not be generating large profits.
    2. Partial Tax Exemption (PTE): For companies that do not qualify for the SUTE scheme, there is the Partial Tax Exemption. This program allows companies to receive a tax exemption on the first SGD 10,000 of chargeable income and a 50% exemption on the next SGD 190,000. This program is available to all companies and offers ongoing tax relief even after the initial three-year startup period.

    Who Can Benefit from These Tax Relief Programs?

    To qualify for the Startup Tax Exemption (SUTE) scheme, companies must meet certain conditions:

    It’s also important to note that the SUTE scheme does not apply to companies engaging in certain industries, such as property development or investment holding.

    The Partial Tax Exemption (PTE) scheme, however, is open to all companies, regardless of their size or shareholders, making it a flexible option for businesses that don’t qualify for the SUTE scheme.

    Why Are These Tax Reliefs Important for Startups?

    Starting a business often involves significant financial challenges, especially during the first few years.

    These tax relief schemes help reduce the tax burden on startups, allowing them to reinvest their profits back into the business.

    This can be particularly beneficial for tech startups, which often require significant capital for research and development (R&D) before they start generating profits.

    By offering tax relief, Singapore encourages innovation and entrepreneurship, helping businesses grow faster and contribute to the country’s economy.

    Conclusion – Singapore’s Tax Relief for Startups

    Singapore’s tax relief programs for startups provide a strong incentive for entrepreneurs to set up their businesses in the country.

    The Startup Tax Exemption and Partial Tax Exemption schemes reduce the financial burden on new companies, allowing them to focus on growth and innovation.

    For entrepreneurs looking to launch a business in Asia, Singapore’s supportive tax environment, combined with its strategic location and infrastructure, makes it an ideal place to start and grow a business.

    Final thoughts

    If you have any queries about this article on Singapore’s Tax Relief for Startups, or tax matters in Singapore at all, then please get in touch.

    US Energy Tax Credits – Nearly $40 Billion Sought 

    US Energy Tax Credits – Introduction

    Energy tax credits are incentives provided by governments to encourage investment in renewable energy, energy efficiency, and other environmentally friendly technologies.

    These credits allow companies and individuals to reduce their tax liability if they invest in qualifying projects, such as solar panels, wind farms, or energy-efficient buildings.

    In the United States, the government has recently made $40 billion available for credits, though the amount requested by companies far exceeds the available funds.

    Let’s explore what this means for businesses and the future of renewable energy.

    The Program

    The US government offers a range of tax credits to support the transition to cleaner energy.

    These credits are part of the Inflation Reduction Act, which aims to reduce carbon emissions and promote sustainable energy projects.

    The most sought-after credits include:

    Both credits are designed to make renewable energy projects more financially viable and attract investment into the sector.

    Demand Exceeds Supply

    According to recent reports, companies have applied for more than $40 billion in credits, far exceeding the amount available.

    This high demand reflects the growing interest in renewable energy projects, driven by both economic and environmental factors.

    However, not all applications will receive funding.

    The government will need to prioritise projects based on their potential impact, technological innovation, and contribution to reducing carbon emissions.

    As a result, companies will face stiff competition for these tax credits.

    Who Benefits From These Credits?

    Large corporations, particularly in the energy, tech, and manufacturing sectors, are the biggest beneficiaries of these credits.

    Companies like Tesla, NextEra Energy, and General Electric have all taken advantage of tax incentives to invest in renewable energy projects.

    But it’s not just large companies that can benefit.

    Small and medium-sized enterprises (SMEs) can also apply for tax credits if they are involved in the renewable energy sector.

    Additionally, individuals who install solar panels or make energy-efficient improvements to their homes may also be eligible for tax credits.

    Challenges in the Process

    Despite the benefits, the application process can be complex.

    Companies must meet strict requirements and provide detailed documentation to qualify for the credits.

    This includes proving that the project is eligible under the specific terms of the credit and demonstrating its potential environmental impact.

    Moreover, as demand continues to outpace supply, companies may need to explore other forms of financing for their renewable energy projects.

    Tax credits are just one part of the broader financial toolkit available to companies investing in clean energy.

    Conclusion

    The strong demand for credits highlights the growing momentum behind the shift to renewable energy in the United States.

    While not every company will secure funding through tax credits, the availability of these incentives is encouraging more businesses to invest in sustainable projects.

    For companies considering renewable energy investments, it’s essential to stay informed about the latest tax credit opportunities and work with experienced advisers to navigate the application process

    Final thoughts

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

    Puerto Rico Tax Incentives: Leveraging Benefits and maintaining compliance!

    Puerto Rico Tax Incentives – Introduction

    Puerto Rico offers attractive tax incentives to lure high-net-worth individuals and businesses to the island, fostering local economic growth.

    The Puerto Rico Incentives Code of 2019, known as Act 60, provides significant tax advantages for those who qualify as bona fide residents and meet certain economic contribution requirements.

    Overview of Act 60

    Act 60 consolidates and updates previous tax incentives, including Act 20 and Act 22, targeting a variety of sectors such as individual investors, businesses, manufacturers, international financial entities, and private equity funds.

    Act 20: Export Services Act

    Act 20 provides tax incentives for companies based in Puerto Rico that export services to other regions.

    Benefits include a fixed income tax rate of 4% on eligible export services and a complete tax exemption on dividends from earnings and profits.

    Eligible businesses must maintain a bona fide office in Puerto Rico and render services to clients outside the island.

    Key Benefits for Act 20 Businesses

    Act 22: Relocation of Individual Investors

    Act 22 offers a 100% tax exemption on dividends, interest, and capital gains for new Puerto Rico residents.

    To qualify, individuals must be bona fide residents, meeting criteria such as spending the majority of the year in Puerto Rico, having no tax home outside Puerto Rico, and showing stronger connections to Puerto Rico than any other location.

    Bona Fide Resident Test

    Additional requirements include an annual $10,000 donation to local nonprofits and purchasing residential property within two years of establishing residency.

    IRS Scrutiny and Compliance

    Due to the generous nature of these tax breaks, the IRS has increased its enforcement efforts to prevent abuse of Act 60 incentives.

    In 2021, the IRS launched a compliance campaign targeting potentially fraudulent claims, focusing on whether individuals and businesses genuinely meet the residency and income sourcing requirements.

    Compliance Tips

    Puerto Rico  Tax Incentives – Conclusion

    Puerto Rico’s tax incentives offer substantial benefits, but they come with strict compliance requirements.

    Properly navigating these can avoid IRS scrutiny and potential penalties.

    For those considering a move to Puerto Rico, consulting with experienced tax attorneys is crucial to optimize benefits and ensure compliance.

    Final thoughts

    If you have any queries on Puerto Rico and its tax incentives then please get in touch.

    Digital Games Tax Offset: What It Means for Video Game Developers

    Digital Games Tax Offset – Introduction

    On June 23, 2023, the Digital Games Tax Offset (DGTO) became law in Australia.

    This new measure aims to support eligible video game developers by providing a 30% refundable tax offset for qualifying Australian development expenditure.

    But what does this mean in practical terms?

    What is a Refundable Tax Offset?

    A tax offset typically reduces the amount of tax a company owes.

    In the case of the DGTO, it’s a refundable offset, meaning if your tax payable is less than the offset amount, the Australian Taxation Office (ATO) will refund the difference.

    For example, if you owe $500 in tax but have a $1000 offset, you’ll receive a $500 tax refund.

    This mechanism effectively allows the government to contribute to and boost the development budget of a video game, provided the company has already spent the money.

    Get Professional international Tax Advice

    Who is Entitled to Claim the Offset?

    To claim the DGTO, the following criteria must be met:

    Qualifying Development Expenditure Includes:

    Excluded Expenditure Includes:

    Geographic Requirement:

    The development expenditure must be Australian, meaning the goods or services are acquired in Australia. This excludes expenses incurred overseas.

    How Much Can Be Claimed?

    A company can claim up to 30% of all qualifying expenditure, with a maximum claimable amount of $20 million per year.

    This cap applies across multiple games. For instance, if three games are developed with a total budget of $90 million, the maximum offset remains $20 million.

    The approximate limit of a game’s budget that can be claimed is around $66.7 million.

    The ATO will group related companies for the purpose of applying the cap, so developing two games from separate companies will have their expenditures added together.

    Certification Requirement

    Before filing an offset claim with the ATO, developers need a certificate (completion, porting, or ongoing) from the Arts Minister. This certificate verifies that all the requirements are met.

    What Counts as a Video Game?

    The definition of a video game under the act is broad, encompassing games in electronic form that can generate a display on:

    Digital Games Tax Offset – Conclusion

    The DGTO is likely to benefit larger developers more than indie developers.

    The minimum threshold of $500,000 in development expenditure will rule out many independent studios, particularly considering the expenditures that do not qualify.

    Therefore, even a game with a budget over $500,000 may not meet the criteria.

    Final thoughts

    If you have any queries about this article on the Digital Games Tax Offset, or Australian tax matters in general, then please get in touch.

    Transfers of Clean Energy Tax Credits – Final rules

    Transfers of Clean Energy Tax Credits – Introduction

    On April 25, 2024, the Internal Revenue Service (IRS) and the Treasury Department issued final regulations (the Final Regulations) for energy tax credit transfers under Section 6418 of the Internal Revenue Code (the Code).

    Section 6418, introduced as part of the Inflation Reduction Act of 2022 (the IRA), allows eligible taxpayers to transfer certain clean energy tax credits to unrelated taxpayers for cash, creating a marketplace for these tax credit transfers and spurring investment in the energy sector.

    Background

    Before the IRA, clean energy tax credits could only be used by taxpayers who owned the underlying clean energy projects, often involving complex tax equity structures typically accessible to large-scale projects and financial institutions.

    The IRA addressed concerns about the sufficiency of the tax equity market to support clean energy adoption by introducing the transferability of clean energy credits, thus creating a broader market for these credits.

    Overview of Section 6418

    Eligible Taxpayers

    Any taxpayer that is not a tax-exempt organization, state, political subdivision, Indian Tribal government, Alaska Native Corporation, rural electricity cooperative, or the Tennessee Valley Authority. These entities can benefit from the direct pay mechanism under Section 6417.

    Transfer Mechanics

    Eligible Tax Credits

    Eleven tax credits are eligible for transfer under Section 6418, including:

    Summary of the Final Regulations

    The Final Regulations, which follow proposed regulations issued on June 14, 2023, adopt rules for making transfer elections with additional clarifications:

    General Rules and Definitions

    Rules for Transferees and Transferors

    Special Rules

    Transfers of Clean Energy Tax Credits – Conclusion

    Section 6418 became effective for taxable years beginning after December 31, 2022, and the Final Regulations take effect from July 1, 2024.

    These regulations provide additional certainty for taxpayers as the market for clean energy tax credit transfers grows. Congress is closely monitoring the performance of this new mechanism, which, if successful, could potentially expand to include other tax credits.

    Final thoughts

    If you have any queries about this article on Transfers of Clean Energy Tax Credits, or US tax matters more generally, then please get in touch. 

    Provisional Measure Limiting Tax Compensation

    Provisional Measure Limiting Tax Compensation – Introduction

    On Tuesday, April 4th, 2024, the Brazilian Federal Government published Provisional Measure (PM) No. 1,227/2024, introducing significant changes to tax regulations.

    As a PM, this measure has the immediate force of law but must be approved by Congress within 120 days to remain effective.

    Key Changes Introduced by PM No. 1,227/2024

    Limitation on Use of Presumed PIS/Cofins Credits

    The measure revokes previous provisions that allowed taxpayers to recover presumed PIS/Cofins credits in cash.

    Under the new legislation, companies can only offset these credits against other federal taxes.

    This change limits the flexibility businesses previously had in managing their tax liabilities.

    Prohibition on Offsetting Non-Cumulative PIS/Cofins Credits

    One of the most controversial aspects of the PM is the prohibition on offsetting PIS/Cofins credits, calculated under the non-cumulative system, with other federal taxes.

    Previously, taxpayers could offset these credits with taxes such as Corporate Income Tax (IRPJ) or Social Contribution on Net Profit (CSLL).

    Now, PIS/Cofins credits can only be offset against debts of the same contributions, although requesting reimbursement in cash is still possible in certain legislatively defined cases.

    Mandatory Declaration of Tax Benefits

    The PM imposes a new obligation on taxpayers to declare their tax benefits.

    Taxpayers must inform the Federal Revenue Service about the incentives, exemptions, benefits, or tax immunities they enjoy, as well as the corresponding tax credit value.

    Failure to report or late reporting of this information can result in fines of up to 30% of the value of the tax benefits.

    Government’s Rationale

    The Government has stated that these measures aim to balance public accounts, particularly in light of payroll tax exemptions.

    To provide further clarity, a Normative Instruction will be issued, detailing the changes, especially those concerning the declaration of tax benefits.

    Implications for Taxpayers

    Provisional Measuring Limiting Compensation – Conclusion

    We would suggest that any taxpayers who might be affected by these changes should seek advice in relation to them.

    Final thoughts

    If you have any questions regarding this Provisional Measure Limiting Compensation, or  other tax matters in Brazil, please get in touch.

    Malta Micro Invest Scheme Relaunch

    Malta Micro Invest Scheme – Introduction

    Malta Enterprise has reinvigorated the local business landscape by reintroducing the Micro Invest Scheme, a strategic initiative aimed at fostering growth and investment among small and medium-sized enterprises (SMEs).

    This tax credit scheme, designed to support businesses in scaling their operations, opens up opportunities for a wide range of entities, including startups, family-owned businesses, and self-employed individuals, to invest more robustly in their future.

    Key Features of the Micro Invest Scheme

    Tax Credit Benefits

    Central to the Scheme is the provision of a tax credit covering 45% of eligible expenditures for businesses across Malta and an enhanced 60% for those operating within Gozo. This significant financial incentive is designed to lighten the fiscal load on businesses as they seek to expand and innovate.

    Eligible Expenditures

    The Scheme covers a variety of investment avenues, including:

    Eligibility Criteria

    To tap into the Scheme’s benefits, businesses must meet certain criteria, including:

    Application Deadlines

    Malta Micro Invest Scheme – Conclusion

    The relaunch of the Micro Invest Scheme by Malta Enterprise signifies a strategic investment in the sustainable growth of the local business ecosystem.

    By offsetting a portion of the investment costs through tax credits, the Scheme not only makes it financially feasible for SMEs to pursue growth initiatives but also stimulates economic activity and job creation within Malta and Gozo.

    As the application window opens, businesses are encouraged to assess their eligibility and consider how the Scheme can support their growth ambitions in the coming year.

    Final th0ughts

    If you have any queries about the Malta Micro Invest Scheme, or Maltese tax matters more generally, then please get in touch.