BDO Corporate Tax News: Issue 69

February 2024

The UAE Federal Tax Authority has released detailed guidance on the tax group rules that clarifies various aspects of the rules, including formation, termination, taxable income and compliance. And in Germany, the Federal Fiscal Court has issued a taxpayer-favourable decision on the fiscal integration requirement under the domestic tax grouping rules, specifically where the controlling company is merged into another entity during the year.

Countries are continuing to implement the Pillar Two rules into their domestic laws. We have updates on HungaryMalaysia and Switzerland, as well as the infringement proceedings in the EU against nine member states for failure to notify the Commission about measures transposing the EU global minimum taxation directive into their domestic laws by the 31 December 2023 deadline.

Recent legislation in Belgium revises the CFC rules to focus on the taxation of passive income of low-taxed entities and Ecuador has introduced a CFC regime. 

India’s interim Union Budget 2024 does not contain any significant tax changes. Malaysia has introduced a broader than expected capital gains tax on the disposal of capital assets and Singapore is now taxing gains on the disposal of foreign assets if economic substance requirements are not met. Guidance released by the Philippines tax authorities on the 1% withholding tax on gross remittances by e-marketplace operators and digital financial services providers reshapes the tax landscape for these entities.

Learn about these developments and be sure to check out the corporate tax rate changes for 2024 and explore BDO’s Pillar Two implementation tracker.