Corporate Tax News: Issue 66 - May 2023

Plans for the implementation of Pillar Two are beginning to take shape in many countries. Australia and New Zealand are the most recent jurisdiction to provide details on the introduction of the 15% domestic minimum tax, Nigeria has committed to the two-pillar solution, Qatar has re-confirmed its commitment to introducing the minimum tax and introduced changes to its corporate tax regime to align its domestic rules with the Pillar Two measures and Switzerland is holding a referendum in June that would allow the measures to be introduced. Are you interested in the “State of Play” of Pillar Two measures? We also include a table that sets out the basics of where countries stand on implementation.

Where does “tax” intersect with ESG initiatives? Arguably, tax represents one of the most tangible representations of ESG in action. One of our lead articles takes a general look at how governments are attempting to crack down on tax evasion and tax avoidance, for example, by looking for more transparency from taxpayers. Singapore has implemented two frameworks that encourage large companies with complex structures/business models to voluntarily adopt good tax governance principles and practices and offer benefits in return. 

In other news:

  • Draft measures in Austria include eagerly awaited tax measures for cross-border reorganisations.
  • Belgium has been tinkering with its tax system and recently proposed a tax reform.
  • France’s highest court has ruled that unused foreign tax credits may not be carried over to future years.
  • India’s doubling of the withholding tax rate on royalties and fees for technical services paid to nonresidents means that many will find themselves facing the additional compliance burden of having to take a treaty position to reduce their withholding tax exposure.
  • A new regulation in Indonesia provides more detail on the incentives available to companies operating in the Special Economic Zones.
  • Both Kenya and Uganda are introducing digital services taxes at rates of 3% and 5%, respectively.
  • Entities in Kuwait (including foreign entities) must identify individuals who are their ultimate beneficial owners, maintain a register of these owners and provide the information to the Kuwaiti authorities. 
  • New Zealand has new tax exemptions for electric bikes and scooters as part of the country's wider environmental efforts. 
  • Romania was one of the first EU member states to transpose the EU public country-by-country reporting directive into its domestic law and its reporting requirements apply starting in 2023.
  • The tax authorities in the United Arab Emirates have been issuing regular guidance on various aspects of the new Corporate Tax Law that becomes operative on 1 June.

Learn about these developments and much more in Corporate Tax News. 

Are you a tax leader in your organisation? We invite you to share your views in BDO’s Global Tax Outlook 2023, our quick survey on how the business of tax is evolving. 

Content adapted from BDO Global.