BDO Global Corporate Tax News

Our final issue of Corporate Tax News for 2024 looks at new incentive regimes in Argentina and Indonesia that offer long-term tax, customs and foreign exchange benefits to investors that commit to make specified investments. 

Pillar Two continues to dominate the tax news (see our Pillar Two update column in this issue):

• Bahrain and Brazil have introduced QDMTTs that are in alignment with the OECD’s GloBE rules, but no IIR or UTPR. Both countries are the first in their respective regions to introduce such a tax.
• Embedded in the 2025 budget proposals in France and the Netherlands are technical amendments to each country’s Pillar Two rules.
• Plans to introduce Pillar Two measures in Kuwait have been accelerated.
• Malaysia continues to be committed to implementing the global minimum tax. 
• Draft legislation approved in Portugal will implement the EU global minimum taxation directive into domestic law.

Meanwhile, the following developments have taken place:

• Canada’s tax authorities have reversed their position relating to the reimbursement of subcontractor fees to nonresidents for services performed in Canada. 
• A tax reform bill in Colombia includes a gradual reduction of the CIT rate but an increase in the alternative minimum tax rate and the introduction of a temporary surcharge on financial institutions. 
• A court in India has ruled on the attribution of profits to a PE in a case involving a profitable Indian PE of a loss-making overseas entity.
• Starting in 2025, nonresidents can directly request a refund of WHT paid on interest income and capital gains from Korea. 
• Norway is introducing limited tax liability on foreigners generating income from aquaculture and related activities and work carried out in the exclusive economic zone and continental shelf.
• The tax authorities in Spain cannot overrule a binding report of the Ministry of Science and Innovation on technological innovation projects qualifying for R&D tax relief.
• The UAE has withdrawn the economic substance regulations. 
• The UK government is following through on its plans to abolish the rules for UK resident non-domiciled individuals and replacing it with a residence-based test.  

Read about these developments and much more in the November Corporate Tax News!

• ARGENTINA: Generous New Incentive Regime for Large Investments
• BAHRAIN: Domestic Minimum Top Up Tax to Apply in 2025
• BRAZIL: Pillar Two Rules Adopted
• CANADA: The CRA’s new position on withholding tax and non-resident contractors
• COLOMBIA: Broad-Based Tax Reform Bill Presented to Congress
• EUROPEAN UNION: 
  • New DAC Proposal Adopted for Exchange of the GloBE (Pillar Two) Information
  • Dutch Interest Deduction Limitation Rule Complies with EU Law According to CJEU
• FRANCE: Corporate Tax Measures in FY25 Draft Finance Bill
• GERMANY: Court Rules Taxation of Foreign Investment Funds Violates EU Law
• INDIA: Profits Attributable to PE Taxable in Source State Even with Global Losses
• INDONESIA: Tax Incentives for Entrepreneurs in Nusantara Capital City Updated
• INTERNATIONAL: 
  • Corporate Tax Bytes
  • Pillar Two Implementation Updates
• KOREA: Procedure for WHT Exemption for Interest Income/Capital Gains to be Relaxed
• MALAYSIA: Highlights of 2025 Budget
• NETHERLANDS: OECD Administrative Guidance to be Incorporated into Global Minimum Tax Legislation
• NORWAY: 
  • Exit Tax Rules to be Tightened Again
  • Tax Liability Proposed to be Extended for Foreigners in the Economic Zone and on the Continental Shelf
• SPAIN: Supreme Court Limits Ability of Tax Authorities to Challenge Binding Reports on Technological Innovation Projects
• UNITED ARAB EMIRATES: Economic Substance Regulations Withdrawn
• UNITED KINGDOM: Autumn Budget 2024