[World Tax News] Norway Publishes Supplementary Tax Act Implementing Pillar 2 Global Minimum Tax and More
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- Last Updated on 20 January, 2024
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Editorial Team – [2024] 158 taxmann.com 449 (Article)
World Tax News provides a weekly snippet of tax news from around the globe. Here is a glimpse of the tax happening in the world this week.
1. Norway publishes Supplementary Tax Act implementing Pillar 2 Global Minimum Tax
On January 12, 2024, Norway officially released the Supplementary Tax Act through the Official Gazette. This legislation incorporates the Pillar 2 global minimum tax, also known as supplementary tax. The Act applies to entities that form part of a Multinational Enterprise (MNE) group with an annual consolidated revenue exceeding EUR 750 million in at least two of the preceding four fiscal years.
It introduces an income inclusion rule (IIR) and a domestic minimum top-up tax, referred to as a national supplementary tax, aiming to establish a minimum effective tax rate of 15%. The Act does not incorporate an undertaxed payment/profit rule (UTPR).
The Supplementary Tax Act prompted revisions to the Tax Administration Act and the Tax Payment Act. These changes encompass the implementation of notification and return obligations concerning supplementary tax, along with corresponding payment requirements. Accompanying regulations specify that the deadline for submitting the supplementary tax notification is 15 months after the conclusion of the financial year. However, this deadline is extended to 18 months for the initial financial year. The supplementary tax return must be filed within one month after the notification deadline, and the supplementary tax payment is expected three weeks after the supplementary tax return deadline.
The Supplementary Tax Act applies to financial years commencing after December 31 2023, specifically starting from the 2024 income year. The corresponding amendments and regulations came into effect on January 1 2024.
Source: Supplimentary Tax Act
2. Russia officially terminates tax treaties with Denmark and Latvia.
On 9th Janauary, 2024, the Ministry of Foreign Affairs of the Russian Federation published an official message for the termination of the Convention between the Government of the Russian Federation and the Government of the Kingdom of Denmark for the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income and property, signed in Moscow on February 8, 1996.
Further, the Russian Federation also terminated the Agreement between the Government of the Russian Federation and the Government of the Republic of Latvia on the avoidance of double taxation and on the prevention of tax evasion in relation to taxes on income and capital, signed in Moscow on December 20, 2010
Source: Official message terminating the Tax Treaty with Denmark
Official message terminating the Tax Treaty with Latvia
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