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BDO Corporate Tax News summarises recent tax developments of international interest across the world.
In this issue:
- Australia:
- ATO issues guidance on treaty shopping arrangements
- U.S. GILTI is not CFC rule for purposes of Australia’s hybrid mismatch rules
- Chile: Fundamental and major tax reform proposed, including new rules for mining companies
- European Union:
- No agreement on compromise text of directive to implement 15% minimum tax and UK defers implementation of Pillar Two
- Report recommends measures for removal of tax-based obstacles to investment in EU
- Gibraltar: Highlights of measures in 2022 budget
- Hong Kong:
- Changes proposed to foreign-source income exemption for passive income
- New tax concessions available for shipping-related activities
- Hungary: Extra profits tax levied on various sectors
- International: Corporate - tax bytes
- Italy: Energy companies subject to one-time contribution on extra profits
- Kenya: Finance Act, 2022 now in effect
- Netherlands: Decree on international tax rulings revised
- OECD:
- OECD extends time frame for completion of Pillar One project, seeks input on new guidance
- OECD Pillar One tax rules pushed back to 2024 as technical work continues
- Pakistan: Finance act, 2022 includes measures affecting businesses and disclosure of beneficial owners
- Saudi Arabia: New six-month tax amnesty announced
- Spain: Temporary windfall profits tax proposed for energy companies and banks
- Uruguay: Definition of beneficial ownership may be expanded
- United Kingdom:
- Energy profits levy on oil and gas sector enacted but actual implementation is unclear
- Draft legislation to implement Pillar Two released
- United States:
- Inflation Reduction Act becomes law
- Termination of Hungary treaty
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