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Despite the “tariff turmoil” of the last few months, several countries have enacted fundamental legislation:
- In a move to attract foreign investment and enhance Hong Kong's status as a financial hub, the new inward company re-domiciliation regime allows qualifying foreign companies to transfer their domicile to Hong Kong while preserving their legal identity and business continuity.
- Ukraine is abolishing its Commercial Code, leaving the Civil Code as the principal legislative act regulating business and civil law relations. The elimination of the code requires businesses to restructure their legal forms.
- The UK has made dramatic changes to the taxation of foreign nationals living in the UK by abolishing the long-standing remittance basis regime and replacing it with a new residence-based test.
- US President Trump signed the One Big Beautiful Bill Act into law in July, marking a substantial overhaul of the international tax landscape in areas such as global intangible low-taxed income, foreign-derived intangible income and the base erosion anti-abuse tax. The act also makes critical changes to other areas of US tax law, including domestic manufacturing, and in addition to an article on the international tax measures, we include an article on the implications for tax planning for manufacturing.
- Vietnam has enacted a new corporate income tax law aimed to modernise the tax framework, with the new rules bringing foreign companies using ecommerce and digital platforms within the tax net.
The Netherlands Supreme Court has issued two decisions that offer useful guidance on the application of the anti-abuse rule in the domestic dividend withholding tax exemption and India’s Supreme Court has released a landmark decision in which it broadens the interpretation of a permanent establishment. Germany has asked the CJEU to rule on the compatibility of the withholding of capital gains tax on dividends paid to companies outside the EU with the EU freedoms.
In Pillar Two news, Liechtenstein has extended the deadlines to submit the first Liechtenstein QDMTT/IIR return and register for Pillar Two purposes, Kuwait has released Executive Regulations for its Pillar Two rules, Mauritius has introduced a QDMTT and the UK has released draft legislation to revise its Pillar Two rules. Also be sure to check out our round-up of Pillar Two updates over the past three months.Learn about these developments and more in BDO’s Corporate Tax News.
In this issue:
- Hong Kong: Company Re-Domiciliation Regime Now in Effect
- United States: New Tax Act Changes Numerous International Tax Provisions
- Czech Republic: Tax Depreciation of PV Plants Now More Flexible and More Complicated
- Germany: CJEU to Rule on Compatibility of Withholding Tax on Third-Country Companies with EU Freedoms
- India: Supreme Court Rules Active Participation and Control Over Core Operations of Indian Entity Constitutes a Fixed Place PE
- International:
- Corporate tax bytes
- Pillar Two Updates
- Kuwait: Pillar Two Regulations issued
- Liechtenstein: Pillar Two Minimum Tax Declaration and Registration Deadline Extended
- Mauritius: Mauritius – Finance Act 2025 Includes Domestic Minimum Top-Up Tax
- Netherlands: Decisions on Anti-Abuse Rule in Dividend Withholding Tax Exemption May Have Broader Implications
- South Africa: Tax Consequences of Loans to Foreign Trusts: Beware the Anti-Avoidance Measures
- Ukraine: Businesses Required to Restructure Following Abolition of Commercial Code
- United Arab Emirates: New Rules on Audited Financial Statement Requirements
- United Kingdom: More Changes Proposed to Pillar Two Rules
- United Kingdom: FIG Regime | How does the UK's tax regime for new residents compare globally?
- United States: Incentivizing Production: What the OBBBA Means for Manufacturing
- Vietnam: New Corporate Income Tax Law Affects Nonresident Businesses