BDO Corporate Tax News - Issue 65

BDO Corporate Tax News summarises recent tax developments of international interest across the world. 

In this issue:

• Belgium: Tax authorities investigative powers expanded
• Canada: CRA revises return for reporting transactions with non-arm’s length nonresidents
• Colombia: New 15% minimum tax and concept of significant economic presence introduced
• Denmark: Supreme Court rules on beneficial owner and tax treaty abuse cases
• European Union:
  • Tax alert: European Parliament revises “gateway” tests in Unshell Directive
  • Tax alert: Member states reach agreement on minimum taxation under Pillar Two, Poland drops reservations
• Germany: Extraterritorial taxation of German-registered IP rights revised
• India: 2023-24 Finance bill contains some measures to encourage investment 
• International:
  • Corporate tax bytes
  • OECD releases additional Pillar Two Guidance
  • Tax rate changes affecting businesses
• Italy: 2023 budget law measures impact MNEs with Italian operations 
• Japan: Global minimum tax to be introduced under 2023 tax reform, along with easing of CFC rules 
• Singapore: Budget 2023 measures include introduction of GloBE rules and domestic top-up tax
• Thailand: Tax concessions for COVID-19-related donations
• United Arab Emirates: Decree-Law clarifies tax treatment of free zone businesses 
• United Arab Emirates: What do the PE rules in the new corporate tax law mean for you?”
• United Kingdom: Spring budget 2023: What business tax changes can we expect?
• United Kingdom: Increasing challenges relating to “allowable purpose” for intragroup loans
• United States: Interim guidance issued on corporate AMT
• United States: Brazil’s proposed transfer pricing legislation has U.S. foreign tax credit implications

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