BDO Corporate Tax News

• Australia: The government announced on 21 March 2025 that crypto-specific taxation legislation will not be introduced, a conclusion that accords with a February 2024 report issued by the Board of Taxation. It was concluded that existing law covers the taxation of digital assets and transactions.
• Bahrain: A draft of the 2025-2026 budget presented to the National Assembly and Shura Council on 2 March 2025 outlines a 12-point action plan designed to foster Bahrain’s financial stability and restore fiscal balance. A key element of the plan is the introduction of corporate income tax for businesses operating in Bahrain and adjustments to VAT rates to generate higher VAT revenues.
• Belgium: The electronic filing deadlines for nonresident companies to file their tax returns in Belgium (i.e., corporate income tax return, tax on legal entities return, etc.) for assessment year 2025 are: 30 September 2025 for companies and entities with a balance sheet date between 31 December 2024 and 28 February 2025 and 29 August 2025 for companies and entities that expect a refund. The department of finance announced the deadlines on 30 April.
• Fiji: The Revenue and Customs Service recently announced a tax amnesty that runs from 1 May through 31 July 2025. During this period, businesses and individuals can file overdue tax returns, amend filed returns, make voluntary disclosures of income, pay outstanding taxes and receive a waiver on most administrative penalties. Certain taxpayers are excluded from the program.
• Finland: The government announced on 24 April 2024 that agreement has been reached on the general government fiscal plan for 2026–2029. Among the planned changes are a reduction in the corporate income tax rate from 20% to 18% starting on 1 January 2027 and an extension of the loss carry forward period to 25 years.
• Hong Kong: The Legislative Council passed the Inland Revenue (Amendment) (Tax Concessions) Bill 2025 on 30 April 2025, which gives effect to the one-time tax concessions in the 2025/26 budget (for prior coverage, see the tax alert prepared by BDO in Hong Kong).
• Ireland: The tax authorities issued a new Tax and Duty Manual - Participation exemption for certain foreign distributions on 6 May 2025 that provides technical guidance on the operation of the participation exemption for foreign dividends. The participation exemption was introduced by Finance Act 2024 and allows companies to claim an exemption from corporation tax on certain distributions made by foreign subsidiaries on or after 1 January 2025.
• Ivory Coast: The tax authorities released guidance on 10 March 2025 on the identification and reporting requirements relating to beneficial owners.
• Kuwait: The statute of limitations for tax claims has been extended from five years to 10 years as from 1 January 2025.
• Latvia: A law passed on 10 April 2025 temporarily exempts nonresident individuals from a 3% levy on the disposal of crypto assets in public circulation. The personal income tax exemption—which will apply for a three-year period from 1 January 2025 through 31 December 2027—aims to attract crypto-asset service providers to Latvia and eliminate obstacles (such as requiring nonresidents to pay the tax and then request a refund).
• Lithuania: A package of tax measures presented by the minister of finance on 16 April 2025 includes an increase in the standard corporate tax rate from 16% to 17%, an increase in the reduced rate from 6% to 7% and an extension of the 0% corporate rate for eligible small businesses from one to two years. If approved, the measures would apply as from 1 January 2026.
• Malta: The Commissioner for Revenue has announced that a Large Taxpayer Office has been set up for companies that employ 50 or more employees in any basis year from 2019 to 2022 or whose annual turnover in any year of assessment from 2020 to 2022 exceeds EUR 20 million and the company fulfils the VAT supplies criterion (i.e., the company reported for VAT purposes a total value exceeding EUR 10 million in domestic supplies and exports for year of assessment 2022). The Large Taxpayer Office will function as a single point of contact for all related queries, which will be handled by a dedicated team of experts.
• Nigeria: The 30% corporate income tax rates for all companies (except small businesses) is maintained.
• Philippines: The Department of Finance has announced that the government is scrapping proposed legislation that would temporarily increase capital gains taxes (as well as gift and estate taxes) due to improved tax collection efforts. Under the proposal, the capital gains tax would have jumped from 6% to 10% for 2025-2030.
• South Africa: The tax authorities published an updated guide on 23 April 2023 to clarify the requirements relating to beneficial ownership.
• Taiwan: Amendments to the Industrial Innovation Act passed by the Congress on 18 April 2025 expand the scope of the investment tax credit for specific industries and enhance tax incentives for start-up fundraising. To encourage the adoption of digital technologies and technology related to the reduction of carbon, products and services related to AI, energy conservation and carbon reduction are added to the scope of the investment tax credit and the upper limit of the credit is increased from TWD 1 billion to TWD 2 billion. The tax incentive period for start-up businesses is extended from two to five years following the date of establishment, the paid-in capital requirement is reduced from TWD 300 million to TWD 150 million and the investment threshold for angel investors is reduced from TWD 1 million to TWD 500,000.

A notice published by the Ministry of Finance on 18 March 2025 confirms the implementation and enforcement of the revised withholding tax rules. As from 1 January 2025, the party responsible for withholding tax on payments is the enterprise/organisation itself, rather than the person in charge of the enterprise/organisation.

• Thailand: A royal decree approved by parliament introduces corporate income tax deductions to support investment in large commercial electric vehicles, including e-buses and trucks. This includes an additional 100% deduction (200% total) for EVs manufactured and assembled in Thailand and an additional 50% deduction (150% total) for imported EVs through 31 December 2025.
• United Arab Emirates: The Ministry of Finance and Federal Tax Authority recently announced that administrative penalties for corporate taxpayers and certain exempt entities that did not comply with their tax registration deadlines may be waived if specific requirements are met.
• United Kingdom: HMRC launched two important public consultations on 28 April 2025: one on potential reforms to transfer pricing, permanent establishments and the diverted profits tax and the other on ways to simplify and modernise HMRC’s approach to dispute resolution, including use of the alternative dispute resolution and statutory review processes. Both consultations run through 7 July 2025.
• United States: The financial crimes unit (FINCEN) of the US Treasury issued an interim final rule on 21 March 2025 that will substantially scale back the reporting requirements under the Corporate Transparency Act. The interim rule narrows the definition of a reporting company, i.e., a company required to report beneficial ownership information to FINCEN, by eliminating the requirement for US companies and US persons to report--only foreign companies registered in the US will have to report, although they will not have to include information on US individuals who are beneficial owners of the business. The reporting rule is designed to help combat money laundering and other crimes. FINCEN intends to finalise the rule in 2025.