BDO Corporate Tax News summarises recent tax developments of international interest across the world.
In this issue:
- Canada: Mandatory disclosure rules are now law
- Czech Republic: Extensive tax changes announced, including hike in corporate tax rate
- European Union: Foreign subsidies regulation now in effect, with upcoming reporting obligation for affected companies
- Germany:
- Proposed legislation to implement a global minimum tax released
- Changes proposed to interest expense limitation rule
- International:
- OECD issues Pillar Two administrative guidance, information return, and STTR guidance
- OECD issues progress report on Two-Pillar plan
- Corporate Tax bytes
- Korea: Implementation of UTPR delayed
- Malaysia: Special Voluntary Disclosure Programme for direct taxes re-introduced
- Netherlands: Netherlands submitted draft bill to Parliament to implement Pillar 2 directive
- South Africa: SARS’ latest take on the meaning of “place of effective management”
- Spain:
- Burden of proof is on tax authorities to show abuse when denying exemption on EU dividends
- DAC 7 implemented and other changes made to tax law
- Switzerland: Pillar Two implementation approved in referendum
- Thailand: BOI relief measures granted to alleviate the impact of the global minimum tax
- Uganda: 5% DST passed and cap imposed on loss carry forwards
- United States:
- Notice 2023-55 offers temporary relief from final FTC regulations
- Asset managers face new potential withholding obligation on sales of interest in their funds