BDO Corporate Tax News - Issue 67

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

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