Highlights of US final and proposed regulations under section 987 and related rules
Australia
A new frontier of transparency for private groups
Expanded local file requires new international tax disclosures
India
Arm’s length principle applies to transactions with nonresident head office
OECD
Deadline extended for comments on toolkit regarding ring-fencing of mining income
Oman
Domestic minimum tax of 15% implemented as from 1 January 2025
United Kingdom
Overview of Pillar Two registration requirements
United States
Corporate alternative minimum tax proposed regulations: Technical corrections
IRS finalizes Form 1099-DA and instructions
Tax treaty round up
Recent developments with respect to the following tax treaties: Andorra-Romania, Armenia-Japan, Bahrain-United Arab Emirates, Bangladesh-Hong Kong SAR, Belarus-Germany, Belarus-Lithuania, Belarus-United States, Croatia-Liechtenstein, Gabon-Türkiye, Kyrgyzstan-Slovakia, and Sierra Leone-United Arab Emirates, plus an update on certain bilateral tax treaties and protocols that are in effect (or were terminated) as from 1 January 2025 with respect to their provisions on withholding taxes.
This publication has been written in general terms and therefore cannot be relied on to cover specific situations; application of the principles set out will depend upon the particular circumstances involved and we recommend that you obtain professional advice before acting or refraining from acting on any of the contents of this publication. Deloitte LLP would be pleased to advise readers on how to apply the principles set out in this publication to their specific circumstances. Deloitte LLP accepts no duty of care or liability for any loss occasioned to any person acting or refraining from action as a result of any material in this publication.
Deloitte LLP is a limited liability partnership registered in England and Wales with registered number OC303675 and its registered office at 1 New Street Square, London, EC4A 3HQ, United Kingdom.
Deloitte LLP is the United Kingdom affiliate of Deloitte NSE LLP, a member firm of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee (“DTTL”). DTTL and each of its member firms are legally separate and independent entities. DTTL and Deloitte NSE LLP do not provide services to clients. Please see About Deloitte to learn more about our global network of member firms.