Supplementary Global Updates – April 2025

Table of Contents

Austria:
Austria: Austria reduced employer contribution to the Family Burdens Equalization Fund to 3.7% effective from January 1, 2025.

Saudi Arabia:
Saudi Arabia: Tax authority announces turnover thresholds and due dates for 20th, 21st, and 22nd waves of phase 2 of the e-invoicing mandate.
Saudi Arabia: Saudi Arabia issues Ultimate Beneficial Ownership (“UBO”) Rules effective from April 3, 2025.

United Arab Emirates:
UAE: Global minimum tax effective from January 1, 2025.

USA:
United States: Florida Department of Revenue releases 2025 reemployment tax rates.

Austria

Austria: Austria reduced employer contribution to the Family Burdens Equalization Fund to 3.7% effective from January 1, 2025

Effective January 1, 2025, the employer’s contribution rate of Family Burdens Equalization Fund (Familienlastausgleichsfonds) (“FLAF”) has been reduced from 3.9% to 3.7%. FLAF is a statutory fund through which various family benefits like reimbursement of child maintenance costs are provided. Employers are required to contribute to this fund at a certain percentage of the employee salary.

The benefit of lower rate of contribution can be availed for the year 2024 as well, subject to meeting certain conditions such as having an explicit provision in collective agreements, work agreements or intimation through internal communication to all employees.

Implication:
Employers should take note of the lower rate of contribution applicable and update their payroll processes accordingly.

Saudi Arabia

Saudi Arabia: Tax authority announced turnover thresholds and due dates for 20th, 21st and 22nd waves of phase two of the e-invoicing mandate.

The Zakat, Tax, and Customs Authority (“ZATCA”) outlined the criteria for taxpayers included in the 20th, 21st and 22nd waves of Phase two under Saudi Arabia’s e-invoicing mandate. These taxpayers are required to integrate their e-invoicing solutions with the Fatoora platform (e-invoicing system developed by ZATCA) by the specified date mentioned in the below table:

Waves Revenue (in 2022, 2023 and 2024) Due date for integration with the Fatoora
20 SAR 1.5 million October 31, 2025
21 SAR 1.25 million November 30, 2025
22 SAR 1 million December 31, 2025

The phase one of the exercise required taxpayers to generate e-invoices discontinuing the physical invoices or computer-generated invoices using excel or other text editing software. Phase two requires the integration of e-invoices with the Fatoora platform.

ZATCA will notify the affected businesses, ensuring they are informed and prepared to meet the deadline.

Implication:
Businesses with annual VAT-taxable turnover exceeding the above-mentioned revenue thresholds should prepare themselves to comply with e-invoicing requirements within the prescribed timelines.

Saudi Arabia: Saudi Arabia issues Ultimate Beneficial Ownership (“UBO”) Rules effective from April 3, 2025.

On February 21, 2025, the Saudi Minister of Commerce (“MoC”) issued the Ultimate Beneficial Ownership (“UBO”) Rules (the “Rules”), requiring all unlisted companies to identify, disclose, and maintain accurate records of their ultimate beneficial owners. The requirement does not apply to public listed companies, state owned enterprises and companies undergoing bankruptcy proceedings. The rules are effective from April 3, 2025, aligning the Saudi Arabia law framework with global transparency standards.

Under newly introduced Ultimate Beneficial Ownership (“UBO”) Rules, an ultimate beneficial owner is defined as any natural person who meets at least one of the following criteria:

  • Holds 25% or more of the company’s share capital, either directly or indirectly;
  • Controls 25% or more of the company’s voting rights;
  • Has the authority to appoint or remove a majority of the company’s board of directors, board members, or chairman;
  • Exercises significant influence over the company’s operations and decision-making; or
  • A legal representative who satisfies any of the above criteria.

If no individual satisfies the above thresholds, the senior management including the manager, a board member, or the chairman will be deemed to be the ultimate beneficial owner of the company.

The key requirements of new rules are as under:

  • Disclosure of UBOs is now mandatory at the time of incorporation.
  • Existing companies must file annual UBO disclosures on their commercial registration anniversary.
  • Companies must maintain a UBO register and report any changes to MoC within 15 days of such change.
  • A failure to meet the above requirements can result in penalties of up to SAR 500,000 or other sanctions under the law.

Implication:
All unlisted entities in Saudi Arabia must enhance internal governance and reporting systems to comply with new UBO obligations or risk non-compliance penalties.

United Arab Emirates

UAE: Global minimum tax effective from January 1, 2025.

The UAE’s Ministry of Finance (“MoF”) issued on February 11, 2025, a Cabinet Decision No. 142 of 2024 on imposition of ‘Top-Up Tax on Multinational Enterprises’ effective from January 1, 2025, introducing global minimum tax. The Cabinet Decision aims to ensure that the Multinational Enterprises (“MNEs”) operating in the UAE pay a minimum tax on profits, thus aligning with the Organisation for Economic Co-operation and Development (“OECD”) Pillar Two Model Rules.

The provisions include:

  • Domestic Minimum Top-Up Tax (“DMTT”) – The domestic minimum top up tax of 15% applies to qualifying companies and permanent establishments (i.e., constituent/ member companies of the group) in UAE having consolidated annual revenues equal to or exceeding EUR 750 million in at least two of the last four fiscal years having an effective tax rate below 15%. The DMTT is effective from January 1, 2025.
  • The Cabinet Decision does not address the implementation of the Income Inclusion Rule (“IIR”) tax or Undertaxed Profit Rule (“UTPR”) tax.
  • A de minimis safe harbour is provided in respect of multinational or national group companies located in UAE with aggregate revenues and profits less than EUR 10 million and EUR 1 million, respectively, on average over a three-year period. Under this exception, the top up tax is presumed to be zero.
  • The transitional simplification regimes – The taxpayers can elect to apply the OECD’s temporary safe harbour based on the country-by-country reporting (“CbCR”). Accordingly, for fiscal years beginning on or before January 1, 2027, and ending before July 1, 2028, top up tax can be presumed to be zero on satisfying any of the simplified tests based on the CbCR.

The filing/ compliance obligations that are due within 15 months from the end of the financial year include the following –

  • Top up tax return and payment (“DMTT return and payment”) – It’s required to be filed by every constituent/ member company or one designated constituent/ member company in UAE with the Federal Tax Authority. The payment is done along with the filing of the return. (Return and payment can be done within 18 months only in case of the first year).
  • Pillar Two Information return and notification – It’s required to be filed by the companies specified in a decision to be issued by the Minister on a later date. It will contain some information pertaining to the company, its overall structure and calculation of the tax rate. The return and notification needs to be filed within 15 months from the last day of the reporting financial year.

Implication:
Businesses should take note of the above changes and comply with them, if applicable.

USA

United States: Florida Department of Revenue releases 2025 reemployment tax rates

The Florida Department of Revenue has released the reemployment tax rates for 2025.

Reemployment tax refers to the tax paid by the employers and the collected tax amount is deposited into Unemployment Compensation Trust Fund, which is utilized for the purpose of reemployment benefits to eligible claimants.

For wages paid in 2025, the minimum tax rate is fixed at 0.1% (USD 7 per employee), while the maximum tax rate is set at 5.4% (USD 378 per employee), based on annual wages up to USD 7,000 per employee.

  • New employers will be assigned an initial rate of 2.7% until they have reported for 10 quarters. After this period, their rate will be calculated based on claims history and payroll data.
  • Employers taking over an existing business may choose to adopt the previous employer’s tax rate, along with any outstanding liabilities.

All contributing employers will receive their annual rate notice by mail. Employers can also access their specific tax rate online through the Florida Department of Revenue’s Reemployment Tax e-file and pay website.

Implication:
Employers should monitor their tax rate to anticipate payroll costs, as rates can vary significantly (from USD 7 to USD 378 per employee).

Shan & Co © (Nucleus is an affiliate of Shan & Co)