April 2024

  • Bulgaria
    • L’OCSE alza le previsioni di crescita economica della Bulgaria

      L'Organizzazione per la cooperazione e lo sviluppo economico (OCSE) prevede un'accelerazione della crescita economica della Bulgaria dall'1,8% nel 2023 al 2,5% quest'anno e al 2,9% nel 2025, soprattutto grazie all'aumento degli investimenti pubblici e ai fondi dell'Unione Europea. L'organizzazione, inoltre, prevede che l'inflazione bulgara rallenterà bruscamente dal 9,5% nel 2023 al 3,0% quest'anno grazie a un calo dei prezzi globali dei prodotti alimentari e dell'energia.

      Secondo le previsioni dell'OCSE, il deficit fiscale aumenterà in modo significativo con ulteriori aumenti di spesa nel 2024. Il bilancio 2024 prevede un aumento della spesa nominale del 12,1%, con una crescita della spesa che riflette maggiori trasferimenti sociali, tra cui un aumento dell'11% delle pensioni minime, insieme a un forte aumento dei salari del settore pubblico. Alla luce di tutto ciò, l'OCSE prevede che il deficit del bilancio pubblico aumenterà dall'1,9% del PIL dello scorso anno al 2,9% del PIL di quest'anno e al 3,1% nel 2025.

      Per il 2024, le esportazioni di beni e servizi dalla Bulgaria dovrebbero crescere del 2,3% dopo un calo dell'1,9% lo scorso anno e aumentare ulteriormente del 4% nel 2025. Dopo un calo del 6,3% nel 2023, le importazioni di beni e servizi dovrebbero crescere del 4,1% quest'anno e del 5,2% nel 2025.

      Fonte: Confindustria Bulgaria

  • China
    • China, The first preferential tax policy for offshore trade is being piloted in Shanghai

      From April 1, 2024, to March 31, 2025, enterprises registered in the China (Shanghai) Pilot Free Trade Zone and the Lingang New Zone shall be exempted from paying stamp tax on contracts of sale and purchase for offshore trade business, according to a notice released by the Ministry of Finance (MOF)and the State Administration of Taxation (SAT) , named by the Notice on the Preferential Stamp Duty Policy for Offshore Trade in the China (Shanghai) Pilot Free Trade Zone and the New Port Area.(Cai Shui [2024]No.8)

      Offshore trade, or documentation processing trade, refers to a trade model in which the goods are transferred directly from the exporting country to the importing country without entering the border of a middle country.

      Without such preferential tax policy, according to the Stamp Duty Law of the People's Republic of China, when an enterprise engages in offshore resale trading, the stamp duty shall be levied on the contracts of both purchases and sales according to 0.03% of the contract amount. This will have no small impact on the profits of offshore trading companies.

      This is the first preferential tax policy issued and implemented by China for offshore business, and the first trial in Shanghai means that China has taken a substantial first step in the exploration and practice of offshore tax system. The introduction of this preferential policy will enhance the confidence of offshore trade enterprises newly settled in Shanghai.

      You may click the following link for the full contents of Notice No.8: https://www.gov.cn/zhengce/zhengceku/202402/content_6931760.htm

    • China, Financial aid backs equipment renewal and trading-in of consumer goods

      China is offering "strong" financial support to promote the large-scale renewal of equipment and the trade-in of consumer goods, and fiscal support from the central government will focus on key areas like new energy vehicles.

      On April 24, 2024, several ministries launched detailed implementation plans for financial subsidy to the trading-in of old cars, up to December 31, 2024, a one-time quota subsidy will be given to individual consumers who scrap high-emissions passenger cars or purchase new energy cars that meet energy-saving requirements as follows:

      • to scrap national III and below emission standard fuel passenger vehicles
      • to scarp new energy passenger vehicles registered before April 30, 2018,
      • to purchase new energy passenger cars that are included in the "New Energy Vehicle Model Catalogue of Vehicle Purchase Tax Reduction and Exemption", or
      • to purchase fuel passenger cars with displacement of 2.0 litres and below

      For scrapping the above two categories of old cars and buying new energy passenger cars, a subsidy of 10,000 yuan; for those who scrap national III and below emission standard fuel passenger cars and buy 2.0 litres and below emission fuel passenger cars, a subsidy of 7,000 yuan.

      The detailed plans were issued in order to implement the spirit of the Action Plan for Promoting Large-scale Equipment Renewal and Replacing Old Consumer Goods with New Ones announced by the State Council in March (Guo Fa (2024) No.7), with the target that as of 2027, the recycling volume of scrap vehicles is expected to roughly double from 2023, and used car transactions will increase by 45 percent.

      According to the Action Plan, detail preferential tax support will be offered for equipment renewal and technological transformation in the industrial sector, such as special equipment for energy conservation, water conservation, environmental protection, and production safety, and particularly digital and intelligent transformation.

      Diacron will keep an eye on any further developments and update you accordingly.

      You may click below link for the Action Plan and detail plans:



    • China, 2024 Tax Department Regulations Formulation Plan was released

      On 8 April 2024, the Tax Policy and Legislation Department of State Administration of Taxation (SAT) announced the “2024 Tax Department Regulations Formulation Plan”, which includes a total of four regulations as follows:

      • Formulation of the “Administrative Measures for Tax-related Professional Services (Trial)”
      • Revision of the “Rules for Tax Administrative Reconsideration”
      • Revision of “Measures for Tax Arrears Announcement (Trial)”
      • Formulation of the “Administrative Measures for the annual Individual Income Tax Reconciliation for Consolidated Income”

      Please kindly note the Plan is SAT level regulation, which exclude high-level laws formulation (such as state council and NPC Standing Committee). We will keep update for any further development.

      You may click below link for the full contents of 2024 Tax Department Regulations Formulation Plan: https://www.chinatax.gov.cn/chinatax/n810214/c102374/c102375d/c5222488/content.html

    • China is further optimizing foreign exchange business processes to facilitate trade

      On 3 April 2024, the State Administration of Foreign Exchange (SAFE) released a notice regarding further optimizing foreign exchange business processes to facilitate trade (Hui Fa [2024] No. 11), effective from June 1, 2024.

      The key facilitating measures in the Circular 11 include:

      1. Easy registration procedures for enterprises. Currently, local branches of the SAFE conduct the registration and approval for trade enterprise catalog administration, after the new Circular, domestic banks will directly handle the registration of enterprises to be listed in the trade enterprise catalog.
      1. Simple receipt/payment procedures for enterprises in Customs special trade. Domestic banks can simplify the procedures for handling foreign exchange receipts and payments for enterprises that are inconsistent with the import and export enterprises within the Customs special supervision areas according to the principle of business expansion.
      1. Generous procedures for special foreign exchange returns for Class A enterprises. Without the need of registration with SAFE, domestic banks may handle special foreign exchange returns for Class A enterprises’ goods trade, including non-original route returns and returns exceeding 180 days, with a single transaction cap of USD200,000.
      1. Optimized procedures for special foreign exchange returns for Class B/C enterprises. Class B and Class C enterprises that meet certain conditions can handle deferred receipts and payments exceeding 90 days after registration with local branches of the SAFE.

      You may click the below link for the full contents of Hui Fa [2024] No. 11:


  • Hong Kong
    • HK, Implementation of Two-Tiered Standard Rates for Salaries Tax and Tax Under Personal Assessment for 2024/25

      The Financial Secretary proposed to implement a two-tiered standard rates regime for salaries tax and tax under personal assessment starting from the year of assessment 2024/25.

      Currently, salaries tax in Hong Kong is calculated at progressive rates from 2 per cent to 17 per cent on taxpayers net chargeable income or at a standard rate of 15 per cent on net income, whichever is lower. The standard rate is normally adopted for high earners.

      In calculating the amount of tax for taxpayers whose net income (before deduction of allowances) exceeds $5 million and whose salaries tax or tax under personal assessment is to be charged at a standard rate, the first $5 million of their net income will continue to be subject to the standard rate of 15% while the portion of their net income exceeding $5 million will be subject to the standard rate of 16%.

      The new regime is expected to affect 12,000 taxpayers, or just 0.6 per cent, and predicted that the move would raise HK$910 million per year for the government.

      Source: ird.gov.hk

    • HK, reducing profits tax, salaries tax and tax under personal assessment for 2023/24

      The Financial Secretary proposed a one-off reduction of profits tax, salaries tax and tax under personal assessment for the year of assessment 2023/24 by 100%, subject to a ceiling of $3,000 per case.

      For profits tax, the ceiling of the tax reduction is applied to each business. For salaries tax, the ceiling is applied to each individual taxpayer; but for married couples jointly assessed, the ceiling is applied to each married couple (i.e. capped at $3,000 in total). For personal assessment, the ceiling is applied to each single taxpayer or married person who elects for personal assessment separately from his/her spouse. If a taxpayer elects for personal assessment jointly with his/her spouse, the tax reduction is capped at $3,000 for the married couple.

      The proposed tax reduction is not applicable to property tax. Individuals with rental income, if eligible for personal assessment, may be able to enjoy such reduction under personal assessment.

      A taxpayer who is separately chargeable to salaries tax and profits tax can enjoy tax reduction under each of the tax types. For a taxpayer having business profits or rental income and electing for personal assessment, the reduction will be based on the tax payable under personal assessment. It might be different from the amount of tax reduction he/she would get if he/she was not assessed under personal assessment. The exact position will need to be evaluated case by case.

      To elect for personal assessment, eligible taxpayers should complete Part 7 of his/her tax return for individuals (BIR60) for the year of assessment 2023/24. Individuals having salaries income only, but no business profits and rental income, need not elect for personal assessment.

      The proposed reduction will reduce taxpayers’ amount of tax payable for the year of assessment 2023/24. Taxpayers should file their profits tax returns and tax returns for individuals for the year of assessment 2023/24 as usual. Upon enactment of the relevant legislation, the Inland Revenue Department will effect the reduction in the final assessment. For any final assessment for the year of assessment 2023/24 issued before the enactment of the law, the Inland Revenue Department will make a reassessment after the enactment. Taxpayers are not required to make any applications or enquiries to the Department.

      The proposed tax reduction will only be applicable to the final tax for the year of assessment 2023/24, but not to the provisional tax of the same year. Therefore, taxpayers are still required to pay their provisional tax on time despite the proposed reduction measure. The provisional tax paid will be applied to pay the final tax for the year of assessment 2023/24 and the provisional tax for the year of assessment 2024/25. Excess balance, if any, will be refunded.

      Source: ird.gov.hk

    • HK updating tax jurisdictions

      The HKSAR Government announces on 30th April that based of OECD recommendations, Hong Kong will amend the list of tax jurisdictions on automatic exchange of financial account information in tax matters (AEOI) under the inland revenue ordinance.

      9 Jurisdictions have been removed from the list as they have yet to activate exchange relationships for AEOI with Hong Kong. Bahrain, Belize, Marshall Islands, Montserrat, Nauru, Niue, Saint Vincent & the Grenadines, Seychelles, and Trinidad & Tobago.

      11 Jurisdictions have been added to the list which have activated exchange relationships for AEOI with Hong Kong. Azerbaijan, Ecuador, Jamaica, Kazakhstan, Kenya, Maldives, Nigeria, Oman, Pakistan, Peru, and Thailand.

      Since September 2018, Hong Kong has conducted AEOI with several other jurisdictions as advocated by the OECD, with the aim to enhance tax transparency and combat cross-border tax evasion.

      Source: news.gov.hk

  • India
    • Investor visas in India: a comprehensive guide

      With its thriving and booming economy, extensively skilled workforce, and diverse industries, India has emerged as a global business hub and continues strengthening its position. The nation is the 5th largest economy in the world - according to the International Monetary Fund- with a Gross Domestic Product (GDP) of $4.1 Trillion. Furthermore, S&P Global estimates that India’s GDP will reach $6.7 Trillion by 2031, making it the third-largest economy globally.

      Policy reforms and infrastructure developments across diverse industries, including manufacturing, information technology, pharmaceuticals, biotechnology, and more, have fortified the consumer base. Thus, India’s robust and expanding consumer market offers lucrative and resilient opportunities for businesses seeking to diversify operations. Moreover, the nation’s abundant natural resources and skilled workforce ensure a streamlined establishment of operations, making it a hub of international commerce and trade.

      Foreign nationals can apply for a variety of visas depending on the purpose of their travel. In 2014, e-visa was introduced, open to more than 166 nationalities. The visa application process has been streamlined and made hassle-free, eliminating the need to visit embassies and physical visa stamping on passports.

      Foreign nationals entering the nation seeking to work in India can fall under two categories: those seeking to work in and from India and those desirous of setting up an industrial/business venture in India. Separate types of visas are granted to the two, with their unique set of tenure, requirements, and eligibility criteria.

      The Different Investor Visas in India

      The two work-related visas for foreign individuals are namely:

      • Business e-Visa, commonly known as a ‘B’ visa
      • Employment e-Visa, widely referred to as ‘E’ visa

      Employment visas are granted to highly skilled and/or qualified professionals drawing a salary of more than $25,000 per annum (with the exception of ethnic cooks, language teachers, translators, and staff working in embassies) seeking employment with an Indian business or organisation. This visa is also given to those professionals already employed by an organisation that has an ongoing project in India.

      However, if a foreign individual seeks to establish or explore the different avenues of establishing an industrial/business venture in India, the Business e-Visa is granted. It covers the buying and selling of industrial products, commercial products, and/or consumer durables.

      Furthermore, foreign individuals should opt for a business visa if they are visiting India:

      • To attend technical, board, or general meetings to provide business services and/or support
      • To recruit manpower from India for their businesses
      • To consult for and/or participate in exhibitions, trade fairs, etc.
      • To serve as a partner and/or function as one of the company’s directors
      • To transact business with suppliers or explore potential suppliers from India, including the evaluation or monitoring quality of the supply chain, placing of supply orders, etc., about the goods or services procured from India
      • To monitor the progress of an ongoing project in India, to conduct meetings with Indian consumers, and/or to provide technical guidance
      • To conduct pre-sales or post-sales activity on a project in collaboration with an Indian business
      • To receive in-house training from a regional hub of a business located in India
      • To conduct business tours for foreigners exploring investment opportunities in India

      Business visas with multiple entry facilities are granted for 5 years and can be further extended for another 5 years. Moreover, nationals from the United States of America are eligible for business visas with a validity of 10 years and a multiple entry facility.

      The Application Process for e-Visas in India

      Applying for a business visa is a simple process. The launch of the e-Visa web portal in 2014 has streamlined the application process for Indian visas. One need only fill in a simple e-Visa application form with the following supporting documents:

      • A valid passport with at least two blank pages and a six-month validity period, along with the appropriate travel documents
      • Passport-sized photos, a letter of introduction/support from a registered Indian business entity
      • A certificate of incorporation of the Indian business entity
      • Proof of financial stability and experience in the industry the business operates under

      Moreover, the family members or dependents of a foreign investor who have been granted a business visa will also be provided with dependent visas. The dependent visas shall have the same validity period as the principal business visa or for such shorter period as may be considered necessary by the Indian Mission.

      Benefits of having an Investor Visa in India

      An Investor Visa in India offers several advantages for foreign entrepreneurs.  Understanding the importance of aligning immigration objectives with investment opportunities, India also grants Permanent Residency Status (PRS) to foreign investors with a business visa.

      To qualify for PRS, a foreign investor must invest at least INR 10 Crore within 18 months or a minimum of INR 250 Cr within 36 months under the FDI route, resulting in employment for at least 20 resident Indians in every financial year. Individuals with investor visas and their families/dependents who have been granted dependent visas are eligible for PRS if they meet the above criteria.

      A PRS with multiple entries is provided for 10 years and a further extension for another 10 years.

      Though most visas are non-convertible, business visas can be converted under the following circumstances:

      • If the business visa holder falls ill, rendering them unfit for travel, the visa may be converted to a Medical Visa
      • If the business visa holder marries an Indian national, the visa may be converted pending the submission of documents certifying the marriage
      • If the holder of the business visa is a person of Indian origin

      Choosing the right visa option

      Choosing from the wide range of visa options for your investment goals is challenging. It necessitates thorough investigation, planning, and preparation. Here are a few things you should look out for:

      • Consider your budget, business interests, and expectations. What are your strengths as an investor, and which domain out of the wide range of industries in India is best aligned with your goals
      • Investigate the visa requirements, minimum investment amounts, industry tax regulations, and residency status criterion for the different visa options available
      • Consult experts and investors who have previously invested in entities based out of India to get a complete picture
      • Ensure that the purpose of the business visa is clearly stated. Detailed information, such as planned meetings, partnerships, supplier negotiations, or business negotiations, is advised to enhance the credibility of the business visa application


      India’s economy is growing rapidly and is expected to become the world’s third-largest in less than a decade. Foreign investors should consider their business's potential growth and the minimum investment requirements to qualify for the various rights and privileges available for business visa holders.

      It’s highly advised that one keeps informed of the requirements and eligibility criteria of the different visas as requested by the Indian embassy or consulate. Ensure that all documents are organised, annotated, and prepared as per requirements to facilitate a seamless application and review process. Furthermore, applications for business visas should advisably be planned to avoid time conflicts and delays.

      Business visas help investors and businesses explore and leverage India's unlimited growth potential and talent pool. With a burgeoning economy, talented entrepreneurs, and a robust infrastructure supporting various industries, India is poised to become the epicentre of global trade and business in the coming decades.

      Source: investindia.gov.in

  • Singapore
    • Singapore, CPF contribution changes from 1 January 2025

      Increase in CPF Ordinary Wage ceiling

      The CPF Ordinary Wage (OW) ceiling will be raised to $8,000 by 2026. The increase took four steps since 1 September 2023 to allow employers and employees to adjust.

      Please refer to the table below for the CPF OW and annual salary ceilings from 2023 to 2026:

      Increase in CPF Contribution Rates

      From 1 January 2025, the CPF contribution rates for employees aged above 55 to 65 will be increased to strengthen their retirement adequacy. The changes apply to wages earned from 1 January 2025:

        Source: cpf.gov.sg
    • Singapore, Tripartite Guidelines that Shape the Right Norms and Expectations Around Flexible Work Arrangements to Come into Effect on 1 Dec 2024

      The Government has adopted all 10 recommendations from the Tripartite Workgroup, establishing mandatory Tripartite Guidelines (TG) on Flexible Work Arrangement (FWA) Requests. The mandatory Guidelines will shape the right norms and expectations around FWAs, by setting out how employees should request for FWAs and use them, and how employers and supervisors should handle FWA requests.

      Effective Date: The Tripartite Guidelines on Flexible Work Arrangement Requests (TG-FWAR) should cover all employees who have completed probation starting December 1, 2024.

      Employee Rights: The guidelines aim to simplify the process for employees to formally request FWAs.

      Employer Discretion: Employers retain the final decision on work arrangements but are expected to follow the guidelines when considering requests.

      Public Service Commitment: The Public Service Division will continue to promote FWAs and follow the guidelines.

      Here follows a brief overview of the 10 recommendations:

      1. The TG-FWAR should establish a clear set of workplace norms around requesting FWAs and considering FWA requests. This will better manage employees’ and employers’ expectations on the process and their respective obligations. These guidelines set out the minimum requirements, and do not preclude employers from adopting more progressive practices.
      2. The TG-FWAR should guide the process of requesting and considering FWAs, and not the outcome of FWA requests.
      3. The TG-FWAR should require employers to properly consider FWA requests based on business grounds, and employees to request and use FWAs responsibly.
      4. The TG-FWAR should only apply to formal FWA requests. Formal requests may be defined as requests that are documented and that contain the information needed for the employer make an informed decision.
      5. The TG-FWAR should cover all employees who have completed probation, the duration of which may be determined by employers.
      6. The TG-FWAR should not require employers to consider FWA requests from jobseekers. However, employers could still state their FWA approach or policy in job advertisements and interviews, to manage jobseekers’ expectations on the FWAs they can provide.
      7. The TG-FWAR should cover all employers, including Small and Medium Enterprises (SMEs). Guides and templates should be provided to help all employers comply.
      8. Adopt an educational and enabling approach to implementing the TG-FWAR, with a focus on equipping employees and employers with the resources and skills to make and properly consider FWA requests respectively.
      9. Strengthen communications and engagement to help employers understand how FWAs can help their businesses and raise awareness of the types of FWAs available. This builds on the progressive practices that were promoted under the Tripartite Advisory and Tripartite Standard on FWAs, which will be replaced by the TG-FWAR and its accompanying resource package.
      10. Provide greater support for employers to build and invest in critical FWA implementation capabilities. Resources and training to build capabilities on FWAs should be scaled up in partnership with key business and employee associations and unions. Resources should be customised to cater for different firm sizes, sectors, and nature of work.
      Should you need further information, do not hesitate to contact us at info@diacrongroup.com

      Source: mom.gov

  • Switzerland
    • Telelavoro e Frontalieri in Svizzera: Quadro Normativo e Implicazioni Previdenziali e Fiscali

      Con l'ascesa del telelavoro nel mondo moderno, il confine tra spazio di lavoro e vita privata si è assottigliato, generando una serie di sfide giuridiche e fiscali, specialmente per i frontalieri tra Italia e Svizzera. In un contesto in cui la tecnologia ha reso possibile svolgere l'attività lavorativa da remoto, i lavoratori transfrontalieri si trovano al centro di un intricato labirinto normativo che coinvolge questioni previdenziali, fiscali e legali. L'evoluzione del telelavoro, accelerata dalla pandemia da Covid-19, ha portato alla luce una serie di lacune nel quadro normativo bilaterale tra Italia e Svizzera, mettendo in luce la necessità di rivedere le leggi esistenti per adattarle ai nuovi modelli di lavoro.

      Negli ultimi anni, il panorama legislativo è stato caratterizzato da una serie di cambiamenti e aggiornamenti, creando confusione e incertezza per lavoratori e aziende.

      In Canton Ticino, ad esempio, il numero di persone che lavorano da casa è in costante aumento, riflettendo una tendenza globale verso forme flessibili di impiego. Tuttavia, il quadro normativo svizzero si è dimostrato inadeguato a regolare adeguatamente il telelavoro, mancando di disposizioni specifiche in materia. Questo ha creato incertezza e ha reso necessarie interpretazioni caso per caso delle normative esistenti.

      Nel caso dei lavoratori frontalieri residenti in Italia e attivi in Svizzera, le implicazioni legali diventano ancora più complesse, con considerazioni fiscali e previdenziali da valutare attentamente.

      Implicazioni Previdenziali

      Secondo il Regolamento CE n. 883/04, i frontalieri residenti in Italia sono soggetti alla legislazione previdenziale dello Stato di residenza, a meno che non svolgano una parte sostanziale della loro attività lavorativa in Svizzera, non dovendo trascorrere più del 24,99% del tempo di lavoro in Italia. Il concetto di "parte sostanziale" è stato oggetto di interpretazione e può influenzare l'assoggettamento alla sicurezza sociale italiana o svizzera.

      Durante la pandemia, le normative europee hanno subito significative modifiche, con sospensioni temporanee delle disposizioni vigenti fino a metà del 2023. Tuttavia, il 1º luglio 2023, la Commissione Europea ha ufficialmente proclamato il nuovo Accordo multilaterale, che ha introdotto un limite del 49,99% per il tempo di telelavoro. Questa nuova soglia ha sostituito quella precedente del 24,99%, offrendo ai lavoratori frontalieri una maggiore flessibilità nella gestione del telelavoro e consentendo loro di operare da casa, nei limiti anzidetti, senza influire sul regime previdenziale. È da notare che l'Italia ha aderito all'accordo solo alla fine di dicembre 2023, rendendolo efficace dal 1° gennaio 2024.

      Implicazioni Fiscali

      L'Italia e la Svizzera, in particolare, hanno affrontato questa questione attraverso le rispettive autorità fiscali, firmando due accordi amichevoli e un Protocollo di modifica dell'Accordo sulla tassazione dei lavoratori “frontalieri fiscali”. L'obiettivo è stato chiarire le regole fiscali applicabili al telelavoro transfrontaliero.

      L'accordo attualmente in vigore, valido sia per il 2024 che per il 2025, stabilisce che i “frontalieri fiscali” possono dedicare fino al 25% del loro tempo di lavoro al telelavoro senza che ciò influisca sul loro trattamento fiscale.

      Tuttavia, per i lavoratori "frontalieri non fiscali", ovvero quelli residenti in Italia che trascorrono la settimana in Svizzera e/o vivono a più di venti chilometri dalla frontiera, le complicazioni fiscali diventano ancora più intricate, poiché nonostante siano considerati frontalieri per tutti gli effetti pratici, questi contribuenti rientrano nell'ambito dell'articolo 15, paragrafo 1 della Convenzione contro le doppie imposizioni tra Italia e Svizzera, e di conseguenza non sono soggetti al nuovo Accordo sulla tassazione dei frontalieri né agli accordi amichevoli firmati in materia di telelavoro dal punto di vista fiscale.

      Una questione rilevante per le imprese è il rischio della "stabile organizzazione", che potrebbe sorgere se i dipendenti in telelavoro creano una presenza fisica significativa per l'azienda nel paese in cui risiedono. Questo rischio può comportare implicazioni fiscali e legali aggiuntive per le imprese.


      Il telelavoro dei frontalieri tra Italia e Svizzera pone alle imprese sfide significative in ambito legale, previdenziale e fiscale. Pur avendo accordi bilaterali che forniscono una guida, rimangono ancora zone di incertezza e complessità. È fondamentale che le imprese comprendano appieno tali implicazioni e adottino le misure necessarie per garantire la conformità fiscale e legale nelle loro attività transfrontaliere.


      Per richiedere ulteriori informazioni in merito vi invitiamo a inviare una mail a info.ch@diacrongroup.com. I nostri consulenti saranno lieti di fornirvi il supporto necessario.

  • Thailand
    • Bank of Thailand keeps interest rate at 2.5%

      Mr. Piti Disyatat, Secretary of the Monetary Policy Committee (MPC), announced the outcome of the meeting on 10 April 2024 as follows.

      The Committee voted 5 to 2 to maintain the policy rate at 2.50 percent. Two MPC members voted to cut the policy rate by 0.25 percentage point.

      The Thai economy is projected to grow in 2024 at a higher rate than the previous year with continued support from private consumption and tourism, along with public expenditure which is anticipated to accelerate for the remainder of the year. Meanwhile, structural headwinds continued to weigh on export recovery. Inflation remains subdued from supply factors and government subsidies and is projected to gradually increase towards the target range by the end of 2024. The majority of the Committee deems that the current policy interest rate is conducive to safeguarding macro-financial stability, and that the effectiveness of monetary policy on resolving structural impediments is limited. Most members thus voted to maintain the policy rate at this meeting, but will monitor uncertainties of economic factors going forward. Two members voted to cut the policy rate by 0.25 percentage point to reflect Thailand’s lower potential growth as a result of structural challenges and to partly alleviate debt-servicing burden of borrowers.

      The Thai economy in the second half of 2023 slowed more than anticipated due to sluggish export recovery, delayed government budget disbursement, and higher-than-normal inventories. The aforementioned downside factors are expected to subside this year, causing the Thai economy to grow at 2.6 and 3.0 percent in 2024 and 2025, respectively, faster relative to the previous year. Such economic expansion is supported by (1) an improvement in the tourism outlook in terms of both the number of foreign tourists and spending per head; (2) continued expansion of private consumption despite having been moderating from high growth last year; and (3) an acceleration of public expenditure in the remainder of the year. In contrast, exports of goods are anticipated to recover only gradually in the second half of this year. The decline in Thai economic growth after the COVID-19 pandemic reflects the impact of structural headwinds on the economy’s potential. Structural impediments, particularly deteriorating competitiveness in the exports and manufacturing sectors, as well as global excess capacity limit the benefits of the global economic recovery on the Thai economy.

      Headline inflation is projected at 0.6 and 1.3 percent in 2024 and 2025, respectively. Meanwhile, core inflation is forecasted to be at 0.6 and 0.9 percent in 2024 and 2025, respectively. The downward revision attributes to the decline in prices of certain raw food items due to excess supply and the decrease in energy prices due to an extension of government subsidies, while the recent negative inflation readings excluding subsidies remained positive. Overall, inflation is anticipated to return to target by the end of this year. In the period ahead, the effect of geopolitical tensions and government subsidies on energy prices should be monitored.

      Overall financial conditions remain stable. The costs of private sector funding via commercial banks and corporate bond markets remain approximately unchanged. Total loans outstanding of businesses and households expand at a slower pace due to debt repayments. Nevertheless, the amount of new loans granted is still growing, indicating overall normal credit functioning. However, some groups of SMEs and low-income households face tighter credit conditions due to financial access difficulties and debt serviceability deterioration due to a slower rebound in income. This is consistent with the outstanding amount of non-performing loans (NPLs) which is expected to gradually pick up, and the likelihood of a surge in non-performing loans is limited. The Committee expresses concern on elevated household debt and recognizes the importance of debt deleveraging, which will help mitigate vulnerabilities in the macro and financial system in the long term. Moreover, the Committee assesses that the effectiveness of monetary policy on resolving financial access issues is limited. The Committee welcomes the Bank of Thailand’s initiatives to accelerate targeted measures, particularly Responsible Lending measures.

      The baht’s volatility when measured against the US dollar increased and depreciated more relative to other regional currencies due to the Federal Reserve’s monetary policy outlook and domestic economic and financial developments. The Committee will continue to closely monitor the volatilities in the foreign exchange market.

      The prevailing monetary policy framework seeks to maintain price stability, support sustainable growth, and preserve financial stability. Most Committee members deem that the policy rate remains consistent with sustaining growth while fostering macro-financial stability in the longer term. Nevertheless, uncertainties on the Thai economy remain high, particularly from export recovery, government budget disbursement, and fiscal stimulus measures. The Committee will closely monitor such developments and take into account growth and inflation outlooks in deliberating monetary policy going forward.

      Source: bot.or.th

    • Thailand, Daily minimum wage will be increased from 1 October 2024

      Mr.Phiphat Ratchakitprakarn, Thai Minister of Labour has confirmed that the minimum wage will be increased up to 400 Baht/Day, effective on October 1, 2024 and will be implemented in all occupations across the country.

      Increasing the minimum wage by 400 baht/day nationwide. It can not be implemented immediately because it requires discussions with the Wage Committee by having Mr. Pairoj Chotiksatien, The Permanent Secretary of the Ministry of Labour is the chairman and must learn various information to see which businesses are ready or not ready from now on, there is still 5-6 months to coordinate assistance to entrepreneurs who are not ready. Especially SMEs, who are the largest holders of labor."

      “The next meeting of the wage committee is scheduled to be held on May 14 when further discussions will be carried out on the 400-baht daily wage proposal

      Mr.Pipat said that The government will adjust the minimum wage for all occupations across the country. Encourage them to move forward." and for the wage hikes. I admit that I have a lot of concerns, but I will have to discuss with the entrepreneurs to see if the entrepreneurs can handle it or if not, how do I want the government to help? This is something that Me and the Ministry of Labour will have to find out more."

        Source: Royal Thai Government Media
  • United Kingdom
    • UK: employment laws are changing

      Several changes to UK employment law take effect from 6 April 2024. 

      These changes come from several pieces of legislation passed in the last two years. 

      All these changes apply to England, Scotland and Wales, but not Northern Ireland where employment law is devolved. 

      Changes to flexible working 

      Employees can now make two rather than one request a year for flexible working, and the deadline for employers to respond to requests has been reduced from three to two months.  

      Employers will also have to explain the reasons for denying any request, and employees no longer have to explain the impact of their request. However, the list of reasons employers can use to deny requests is remaining the same, including factors such as cost to the business or impact on quality, performance or ability to meet customer demand. 

      These changes were made through the Employment Rights (Flexible Working) Act 2023Through a separate piece of secondary legislation, employees will also be able to make such requests from their first day of employment, without having to wait the 26-week qualifying period. 

      Carer’s leave 

      Employees are now entitled to take one week of unpaid leave a year if they have caring responsibilities. 

      This applies to any employees who are caring for a spouse, civil partner, child, parent or other dependant who needs care because of a disability, old age or any illness or injury likely to require at least three months of care. The leave entitlement is available from the first day of employment with no qualifying period. 

      This entitlement was created by the Carer’s Leave Act 2023 and the associated Carer’s Leave Regulations 2024

      Increased protection against redundancy for pregnant employees 

      Employees taking certain types of parental leave now have protection from redundancy for at least 18 months. This protection means that if their role is made redundant their employer must give them first refusal of any other vacancies; however, they can still be made redundant if no appropriate vacancy is available. Previously, employees only had this protection during their period of maternity, adoption or shared parental leave.  

      Protection now begins on the day the employer is first notified of the employee’s pregnancy and ends 18 months after the date of the child’s birth. These protections also now extend to 18 months after the date of adoption for parents taking adoption leave or 18 months after the child’s birth in cases where a parent is taking at least six weeks of shared parental leave. 

      These changes were made by the Protection from Redundancy (Pregnancy and Family Leave) Act 2023, and the Maternity Leave, Adoption Leave and Shared Parental Leave (Amendment) Regulations 2024 

      More flexibility for paternity leave 

      Employees taking statutory paternity leave (and pay, if they are eligible) can now split their two weeks’ entitlement into two separate one-week blocks, rather than having to take them both together. They can also take their two weeks at any time within the first year after their child’s birth, rather than within only the first eight weeks after birth as previously required. 

      Employees now have to give employers 28 days’ notice for each week of leave, down from 15 weeks’ notice previously, before taking leave. However, they still need to give notice of their upcoming entitlement 15 weeks before the expected date of birth. 

      These changes were made by the Paternity Leave (Amendment) Regulations 2024. 

      Source: gov.uk

    • UK: Paternity pay and leave

      The amount of leave an individual can take depends on when the baby is due.

      If the baby is due before or on 6 April 2024, or before 6 April 2024 for adoptions

      You can choose to take either 1 or 2 weeks’ leave. You must take your leave in one go. You get the same amount of leave even if you have more than one child (for example, twins).

      A week of leave is the same amount of days that you normally work in a week. For example, if you only work on Mondays and Tuesdays, then a week of leave is 2 days.

      Your leave cannot start before the birth. It must end within 56 days of the birth (or due date, if the baby is early). The start and end date rules are different if you adopt.

      You must give your employer 28 days’ notice if you want to change your start date.

      You do not have to give a precise date when you want to take leave. Instead you can give a general time, such as the day of the birth or one week after the birth.

      If the baby is due after 6 April 2024, or on or after 6 April 2024 for adoptions

      You can take either 1 or 2 weeks’ leave. If you choose to take 2 weeks, you can take them together or separately. You get the same amount of leave even if you have more than one child (for example, twins).

      A week of leave is the same amount of days that you normally work in a week. For example, if you only work on Mondays and Tuesdays, then a week of leave is 2 days.

      Your leave cannot start before the birth. It must end within 52 weeks of the birth (or due date, if the baby is early). The start and end dates rules are different if you adopt.

      You must give your employer 28 days’ notice if you want to change your start date.

      You do not have to give a precise date when you want to take leave. Instead you can give a general time, such as the day of the birth or one week after the birth.

      There are different rules if you live in Northern Ireland.

      Shared Parental Leave

      You may also be eligible for Shared Parental Leave (SPL). You cannot take Paternity Leave after you take SPL.

      Leave for antenatal appointments

      You can take unpaid leave to accompany a pregnant woman to 2 antenatal appointments if you’re:

      • the baby’s father
      • the expectant mother’s spouse or civil partner
      • in a long-term relationship with the expectant mother
      • the intended parent (if you’re having a baby through a surrogacy arrangement)

      You can take up to 6 and a half hours per appointment. Your employer can choose to give you longer.

      You can apply for leave immediately if you’re a permanent employee. You’ll need to have been doing a job for 12 weeks before you qualify if you’re an agency worker.

      Leave for adoption appointments

      You can take unpaid leave to attend 2 adoption appointments after you’ve been matched with a child.

      You can take up to 6 and a half hours per appointment. Your employer can choose to give you longer.

      You can apply for leave immediately if you’re a permanent employee. You’ll need to have been doing a job for 12 weeks before you qualify if you’re an agency worker.

      Source: gov.uk

  • United Arab Emirates
    • Federal Tax Authority Publishes Tax Guide on Business Restructuring Relief

      The Federal Tax Authority (FTA) has published a tax guide designed to provide general guidance on Business Restructuring Relief available under Article 27 of the UAE Corporate Tax Law and provides clarification on the following aspects:

      • the transactions covered within the scope of the relief;
      • the conditions to be eligible for the relief;
      • the consequences of electing the relief;
      • the circumstances in which the relief will be clawed back;
      • the consequences of clawback of the relief;
      • the compliance requirements; and
      • the interaction with other provisions of the UAE Corporate Tax Law.

      The Corporate Tax on business has been introduced by Federal Decree-Law No. 47 of 2022 on the taxation of corporations and businesses issued on 3 October 2022 and applicable to tax periods commencing on or after 1 June 2023.

      Source: IBFD Tax Research Platform news

  • United States
    • US: Underpayment Penalties Waived for Corporate Alternative Minimum Tax

      Under Notice 2024-33, the IRS is waiving underpayment penalties for the first quarterly estimated income tax payment for the corporate alternative minimum tax (CAMT) that is due on or before 15 April 2024 or, in the case of a fiscal year taxpayer with a taxable year beginning in February 2024, 15 May 2024 (see Note).

      Note: The CAMT was implemented under the Inflation Reduction Act (IRA), which imposes a 15% minimum tax on the adjusted financial statement income (AFSI) of large corporations

      Source: IBFD tax research platform news

    • US: IRS Proposes Regulations to Implement 1% Excise Tax on Corporate Stock Repurchases

      The IRS has issued proposed regulations (REG-115710-12, RIN 1545-BQ59 and REG-118499-23, RIN 1545-BQ60), which would implement the 1% excise tax on corporate stock repurchases enacted by Congress under the Inflation Reduction Act (IRA).

      The proposed regulations are derived from - and once finalized would replace - interim guidance issued by the IRS in December 2022.

      The excise tax will apply to stock repurchases that occur after 31 December 2023 and is based on the aggregate fair market values of the stock.

      Under the proposed regulations, a statutory netting principle is implemented, in which the total fair market value of the stock issued by a taxpayer in a fiscal year is deducted from the total fair market value of the stock that the same taxpayer repurchased in that year.

      The regulations would also implement a statutory de minimis exception, which exempts a taxpayer from the stock repurchase excise tax for a fiscal year if the total fair market value of the stock that the taxpayer repurchased in that year is not more than USD 1,000,000.

      Source: IBFD tax research platform news