BDO Corporate Tax News - August 2022

BDO Corporate Tax News (former World Wide Tax News) summarises recent tax developments of international interest across the world. The newsletter highlights the latest tax news with an emphasis on corporate international tax. See all the topics from the links below.

In this month’s issue:

• United Kingdom - Energy profits levy on oil and gas sector enacted but actual implementation is unclear
• Australia - ATO issues guidance on treaty shopping arrangements
• Australia - 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 - Report recommends measures for removal of tax-based obstacles to investment in EU
• European Union - No agreement on compromise text of directive to implement 15% minimum tax and UK defers implementation of Pillar Two
• Gibraltar - Highlights of measures in 2022 budget
• Hong Kong - Changes proposed to foreign-source income exemption for passive income
• Hong Kong - 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 - 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
• United Kingdom - Draft legislation to implement Pillar Two released
• United States - Inflation Reduction Act becomes law
• United States - Treasury makes rare move to terminate tax treaty with Hungary amid minimum tax debate
• Uruguay - Significant changes proposed to source rules for passive income