BDO Corporate Tax News

International - Corporate Tax Bytes

International
  • Australia: The 2026–2027 Federal Budget released on 12 May 2026 proposes a broad package of tax reform measures aimed at supporting businesses and individuals and longer-term fiscal sustainability. Measures affecting businesses include enhanced loss use rules, changes to the R&D tax incentive and expanded venture capital tax incentives (for an analysis of the budget measures, see the tax alert prepared by BDO in Australia).
  • Bahrain: The National Assembly is considering draft legislation that would introduce a 10% corporate income tax on companies with annual revenue exceeding BHD 1 million or net profits above BHD 200,000. The tax would apply only to profits exceeding the BHD 200,000 threshold and, if enacted, would take effect in 2027.
  • Belgium: The tax authorities announced on 30 April 2026 that the e-filing deadlines for corporate income tax returns, tax on legal entities returns and nonresident company returns for assessment year 2026 is 30 September 2026 for companies and entities with a balance sheet date between 31 December 2025 and 28 February 2026. Taxpayers expecting a refund must file by 28 August 2026 to receive priority processing.
  • Botswana: The government has proposed an increase in the corporate income tax rate from 22% to 24.5%.
  • Canada: On 26 March 2026, the Department of Financed announced legislative approval confirming significant changes to the Scientific Research and Experimental Development (SR&ED) investment tax credit program. The changes aim to boost R&D investment, simplify administration of the SR&ED program and reduce claims processing periods (for more information, see the tax alert prepared by BDO in Canada).
  • Finland: The Ministry of Finance’s financing proposal for 2027-2030, published on 26 February 2026, includes a reduction of the corporate income tax rate from 20% to 18% beginning in 2027.
  • Italy: The Supreme Court ruled on 7 Ma 2026 that the dividend withholding tax exemption under Italy’s domestic implementation of the EU parent-subsidiary directive may apply even if the required documentation is submitted after the dividends are paid, confirming that substantive conditions prevail over formal requirements.
  • Kazakhstan: A new whitelist of 41 jurisdictions deemed not to have a preferential tax regime took effect on 21 March 2026 and applies for the two-year period 1 January 2026 through 31 December 2027. Jurisdictions qualify for inclusion on the whitelist if they have a tax treaty with Kazakhstan and a nominal corporate tax rate exceeding 75% of the corporate income tax rate in Kazakhstan.
  • Panama: The National Assembly is reviewing draft legislation that would introduce economic substance requirements for multinational groups in Panama that earn passive foreign-source income. Covered entities would need to maintain adequate qualified staff, have physical premises, incur actual expenses and make strategic decisions in Panama, and submit a sworn declaration of compliance. Noncompliance would trigger a 15% tax on the relevant passive income. The measure is intended to support Panama’s removal from the EU list of noncooperative countries. If enacted, the new rules would apply from the fiscal year that starts after the law is published.
  • Poland: DAC8 and DAC9 have been implemented into Polish law.
  • Qatar:
    • Amendments to the tax law introduce new provisions facilitating business restructuring for both MNE groups subject to the GloBE rules and other taxpayers. As from 1 March 2026, taxpayers may request approval from the General Tax Authority for restructuring relief, with approval deemed granted if no response is received within 30 days.
    • As from 16 March 2026, nonresident recipients of Qatar-source income may request direct application of treaty-based withholding tax rates, avoiding withholding at source and subsequent refund claims. Direct application requires the payer to be an “approved debtor,” meaning that it is registered with the Qatari tax authorities (more criteria is expected) and the nonresident recipient to certify treaty residence, beneficial ownership and compliance with treaty anti-abuse rules.
  • South Africa: The 2026 budget speech delivered on 26 February 2026 emphasises continuity. The corporate income tax rate remains at 27%, dividends tax remains 20% and the capital gains tax inclusion rate for companies remains 80%.
  • Ukraine: The government is holding a public consultation on a bill aligning Ukraine’s tax law with EU Anti-Tax Avoidance Directives (ATADs) and certain OECD BEPS recommendations. The bill—which would apply as from 1 January 2028—includes provisions that would restrict the deduction of interest to 30% of EBIDTA (i.e., taxable earnings before interest, taxes, depreciation, and amortisation; tax capital gains arising from asset transfers outside Ukraine, or changes in residence; introduce anti-avoidance rules; and neutralise hybrid mismatches.
  • United Arab Emirates: The UAE has introduced an R&D tax credit regime, effective from tax periods or fiscal years beginning on or after 1 January 2026 (for an analysis of the measures, see the tax alert prepared by BDO in the UAE).
  • United States: Proposed regulations were released on 10 April 2026 for the new excise 1% remittance transfer tax that applies to remittances sent from the US to recipients in foreign countries when the sender provides cash, a money order, a cashier's check or other similar physical instrument to the remittance transfer provider. The sender is liable for the remittance transfer tax, and remittance transfer providers must collect the tax, make semi-monthly deposits and file quarterly returns with the IRS. If the remittance transfer provider does not collect the tax from the sender, the tax becomes a liability of the remittance transfer provider. (See the tax alert prepared by BDO in the USA).