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 enthusiastic) 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

Canada / Fees in relation to failed acquisition are taxable

The Federal Appeals Court has ruled that fees received by a corporate taxpayer as a result of a failed acquisition of shares in another corporation constitute taxable income. In the case at hand, the taxpayer previously received commitment fees and con-completion fees in the context of a failed acquisition a publicly-traded corporation.

Further information on the decision can be found HERE.

Belgium / Mandatory E-Invoicing for B2B proposed

The Belgian government has released a draft law foreseeing the introduction of mandatory structured electronic invoicing in Belgium for B2B transactions. If voted, the law is planned to come into effect as from 1 January 2026. More information can be found HERE.

Italy / Reform of international taxation

Italy has officially published Decree n°209/2023. The decree implements a reform of the domestic rules relating to international taxation. Inter-alia, the decree brings changes to the “place of effective management” definition as well as to the CFC rules and the participation exemption regime. An overview of all changes can be accessed HERE.

Brazil / Minimum wage increases for 2024

As of 1 January 2024, the minimum wage in Brazil has increased and is now set at BRL 1,412. Further information is available HERE.

Singapore / New CRS guidance published

The Inland Revenue Authority of Singapore published on 12 of January 2024 its updated e-Tax Guide on the Common Reporting Standard. The new e-Tax Guide can be downloaded HERE.

Fun Tax Fact 😂

For this week’s fun tax fact we are going back in history and to land in Europe in the dark middle ages. It was in that time, that many European countries imposed a tax on…SOAP. Maybe this tax explains why we often think that people in the middle ages must have been smelly.

Interestingly enough, the soap tax was abound in the UK only 141 years after its introduction (in year 1838). Don’t believe it? You can find the repealing decision HERE.

Global minimum tax / Pillar 2 bootcamp

Let’s look at some of the basic definitions that seems obvious, but are important to understand for the new global minimum taxation.

What is a “Group”?

The term “Group” means a collection of enterprises related through ownership or control such that it is either required to prepare consolidated financial statements for financial reporting purposes under applicable accounting principles or would be so required if equity interests in any of the enterprises were traded on a public securities exchange.

What is an MNE Group?

The term “MNE Group” means any Group that includes two or more enterprises the tax residence for which is in different jurisdictions or includes an enterprise that is resident for tax purposes in one jurisdiction and is subject to tax with respect to the business carried out through a permanent establishment in another jurisdiction.

Leadership principles for top managers at Big Multi Inc. 🏢

Rule #2 - Have a leadership vision!

Every great leader needs to have a leadership vision that they can repeatedly bring up in team meetings and when they prepare a presentation to higher management.

Leaders love spending their time concentrating and polishing their vision. This includes most time having lunch and playing golf with other leaders, or attend boring week-long conferences where they can to exchange on their visions with others. But the main pillars of a good vision are the following;

• the vision needs to convince the employees that the leader and only the leader knows the future, but he is kind enough to share it with everyone,

• the vision needs to be a simple phrase or sentence, but it must cover a widely complex series if ideas that takes at least 15 minutes to explain, and

• employees must believe that whatever the Company is going to invest in or do in the future to make the vision reality, it is in fact only for the benefit of the employees.

Tax meme of the week

Coffee corner ☕

Does the size of the cup matter?

If you like to start the morning with a longer coffee like a filter coffee, you need a proper coffee mug. If you prefer a shorter type of morning coffee to kick off, you probably have your regular cup to enjoy your espresso, doppio, cappuccino, wiener melange or café crème. If  you are a real aficionado you even have different cups for each of these types of cups. 

Does size matter? Yes, of course - like in many other areas of our everyday life… Naturally for a cappuccino you need a bigger cup than for an ristretto, but there are many other reasons too. In a bigger cup, your lovely morning brew gets colder quicker (if you preheat your cup before servicing or you use a double-walled cup you can naturally delay this) and the temperature of the drink is essential to have the maximum level of joy in your balcony or in your kitchen.

Your cup needs enough room for the whipped cream or the hot milk and foam. Sensing the smell of the crema and enjoying the fresh fragrances of the coffee are important parts of coffee tasting and your morning ritual. Imagine when you move your cup full of freshly made coffee toward your face, the smell of the aromas coming from the coffee is the first thing you experience, the flavor of the coffee only comes second. Therefore, if your cup is not of the proper size, such first experience can be ruined. Who would do such a horrible thing?

Naturally, some days you may not be able to follow this ritual, just simply want to have a big mug of filter coffee without overthinking which cup to use. But carefully selecting what kind of coffee beans you grind is a must!  

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