Greetings and Happy Tuesday! This is Tax Roast, a weekly newsletter that brings you the latest updates and insights from the international tax world from tax experts (and coffee enthusiasts) who are walking the tax advisory path.

And do not forget to check out our coffee of the week, because there is no tax news without a good cup of coffee :)

International Tax Update

United States / IRS asks for public recommendations for 2024/25 priority plan

The Treasury Department and the IRS have invited the public to submit recommendations for items to be included in their 2024-2025 Priority Guidance Plan. The plan’s aim is to provide a roadmap for the Department and the IRS's efforts in addressing critical tax policy issues, including clarifying ambiguous areas of tax law.

recommendations can be submitted ONLINE until 31 May 2024.

Poland / Malta / Opinion issued on BEFIT

Poland and Malta have provided reasoned opinions (HERE and HERE) examining whether the BEFIT Proposal is compatible with the European Union's principles of subsidiarity and proportionality.

Reasoned opinions enable EU national parliaments to notify the Commission of their belief that a proposal violates the subsidiarity principle. In the subsidiarity procedure, each national parliament has two votes on the Commission's proposals, and if reasoned opinions constitute at least one-third of the total votes, the Commission is obligated to review the proposal.

Colombia / Updated WHT return

The Colombian National Tax Authority has modified the withholding tax return form No. 350 (declaración de retenciones en la fuente) to include a specific concept for payments made to non-residents with significant economic presence (presencia económica significativa, PES), as established by the latest tax reform. The new form will be applicable as from 1 August 2024.

New Zealand / Parliament recommends GloBE rules to start in 2025

The New Zealand parliament has recommended various changes to the Taxation Bill. These recommendations include that the GloBE rules take effect in 2025 in New Zealand. In detail, the parliament recommended:

• Applying the GloBE rules for a fiscal year, rather than a time to be specified in an Order in Council;

• specifically stating the starting dates of the GloBE rules, as follows:

  • 1 January 2025 for the income inclusion rule and under-taxed profits rule; and

  • 1 January 2026 for the domestic income inclusion rule.

Fun Tax Fact of the Week

Global minimum tax / Pillar 2 bootcamp

Let's talk about the core elements of Pillar 2. We have two important rules: the Income Inclusion Rule (IIR) and the Undertaxed Profits Rule (UTPR).

Under the IIR, if a company's tax rate in any jurisdiction is below 15%, the main parent company is responsible for paying a 'top-up tax' to bring the rate up to 15%. This ensures fairness and helps maintain a level playing field.

As a backup, we have the UTPR. This rule allows us to allocate a top-up tax to another company within the same group for profits that are not covered by the IIR. This way, we make sure that all profits are properly taxed.

In addition to these rules, a country can also choose to implement a Qualified Domestic Minimum Top-up Tax (QDMTT) alongside the IIR. This gives the country the right to tax low-taxed profits, instead of those profits being taxed in the parent company's jurisdiction or a sister jurisdiction under the UTPR.

Now, I know all this talk about taxes and calculations can be a bit overwhelming. But don't worry, we'll dive into the details next week. Stay tuned!

Take care and have a great day!

Leadership principles for top managers at Big Multi Inc. 🏢

Rule #10 - Team building

Well, congratulations on being the master of all things including the team building! I mean, who needs professional event planners when you can just whip up a fantastic team building event in your spare time, right? So here's a tip for you: make sure to completely disregard the interests and preferences of your team members. After all, who cares if they actually enjoy the activities you plan? After all, nothing says team bonding like watching your employees suffer through a pottery class when they'd rather be anywhere else. Anyway, it's all about asserting your dominance and showing them who's in charge, am I right?

Make sure to schedule the team building during the busiest time of the year. Who needs productivity when you can disrupt everyone's workflow and add unnecessary stress? Your team will surely appreciate the added pressure and chaos.

Finally, don't forget to make the team building event as generic and uninspiring as possible. Who needs creativity and innovation when you can just stick to the same old tired activities that everyone has done a million times before? Forget about trying something new or exciting, because that would require effort and imagination. Stick to the tried and tested formula of boring presentations, mind-numbing lectures, and mindless team-building clichés. Your team members will surely be thrilled to spend their precious time engaging in activities that have been done to death.

Tax Roast of the week

Invite the crew for a coffee☕

We never say no to a good cup of coffee! So, if you loved this edition and you would like to support us, you can invite our crew for a cup of coffee here.

Coffee corner

If you like to start your day with a long coffee, you have nice options such as a filter coffee or a French press coffee. What is a French press coffee maker and how does it work? 

A French press is practically a glass pot with a plunger and a built-in metal filter through which you can press the hot water through the ground coffee. Unlike in a typical filter coffee maker where hot water drops through the ground coffee in a paper filter, in a French press the ground coffee is fully immersed in the hot water and can stay there as long as you want. 

The French press gives you lots of freedom when preparing your morning coffee: how finely ground the coffee should be, what the best water/coffee ratio could be, how hot the water should be when pouring on the coffee powder, how long the coffee should be immersed, etc. French press is an inexpensive coffee maker where your creativity and patience would result in beautiful dark brown long morning coffee with a rich taste.  

Some best practice tips for beginners: 

• Do not use boiling water. Water temperature of c. 90-93 °C / 195-200 °F will do greatly. 

• Start with a coffee-to-water ratio in the range of 1-to-12 and 1-to-15; if you like your coffee even longer you can go for a ratio of 1-to-18.

• Naturally, different people have different tastes, but in a French press typically a stronger and darker roast should be used to let the brew provide rich, dark and earthy flavor.

• Once you have selected your favorite coffee beans, use a coarse grinding, avoid fine grinding that is more suitable for other coffee makers.

• Wait at least 4 minutes when you do a French press for the first time, the typical brewing time is between 4 and 7 minutes.

• Lastly, stirring the coffee a few times before pressing the plunger down helps to make your brew even more tasteful.

Enjoy your morning coffee!

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