BDO Corporate Tax News August 2022

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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