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BDO Corporate Tax News - Issue 63

23 August 2022

Original content provided by BDO

Dr. Henrik Meyer, Certified Tax Advisor, Lawyer, Partner, Head of International Tax Services |

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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