April 15 Tax & Private Wealth Group Key Takeaways

Published on Apr 23, 2025

WLG colleagues in the Tax & Private Wealth Group met on April 15 to discuss global tax updates and opportunities for collaboration. 
Here are the key takeaways from the updates provided:

Singapore:
  • Implemented OECD Pillar Two, actively reviewing policy in light of current trade tensions
  • Introduced corporate tax rebates and extended international business expansion incentives
  • Launched stock market stimulation initiatives with tax incentives for new listings
  • Competitive family office regime with high-threshold requirements
 
Malaysia:
  • Introduced a 2% dividend tax for individual shareholders with annual dividend income over RM100,000
  • Implemented capital gains tax with a 10% rate on unlisted shares
  • Launched special family office incentives in Johor’s Forest City (0% tax for 10 years)
  • Comparative family office strategy positioning against Singapore
 
Philippines:
  • Significant tax code amendments through the "Ease of Paying Taxes” Act
  • Uniform VAT implementation now requires tax payment upon invoice issuance
  • Introduced 12% VAT on digital services for non-resident providers
  • Mandatory online registration for digital service providers
  • Preparing a potential excise tax on single-use plastics and stock transaction tax adjustments
 
Poland/EU:
  • Adopted the DAC Nine directive to simplify Pillar Two implementation
  • Standardizing top-up tax reporting through centralized filing
  • Implemented local minimum tax regime with sector-specific waivers
 
Canada:
  • Potential US tax policy risks, including Section 891 allowing double tax rates on countries with "unfair” taxes
  • Ongoing trade tensions with potential 25% tariffs on certain goods
  • Proposed US legislation for an additional 20% withholding on US-source income for non-residents
 
South Africa:
  • Proposed VAT rate increases (0.5% increments in 2025 and 2026)
  • Increased tax authority scrutiny on high-net-worth individuals and trust structures
  • Growing trend of asset externalization to tax-efficient jurisdictions like Dubai
 
Cross-Jurisdictional Insights:
  • Emerging global trend of digital service taxation
  • Increasing importance of the Principal Purpose Test in treaty interpretation
  • Growing geopolitical impact on international tax strategies
  • Jurisdictional competition for high-net-worth capital through targeted incentives