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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