Belgium Submission of returns: On 30 September 2022, the Belgian Ruling Commission announced filing and prefiling requests related to the innovation income deduction and transfer pricing. According to the announcement, all prefiling requests related to corporate income tax returns for the fiscal year (FY) 2023 must be submitted to the commission by 30 November 2022.
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Colombia Rates-Surtax: On 6 October 2022, the Colombian Congress approved Tax Reform Bill in the first debate. The financial institutions will be subject to surtax at the rate of 5% for a period of 5 years from the fiscal year 2023 to 2027, natural resources exploitation sector 10% for 2023, 7.5% for 2024 and 5% onwards, and hydro energy generation sector 3% from the fiscal year 2024 to 2026.
Withholding rates-Dividends: Dividends paid to nonresident entities would be subject to a 20% withholding tax rate.
Taxation of capital gains: The capital gains tax rate would be increased from 10% to 15%.
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Greece Submission of returns: On 21 October 2022, the Greek Public Revenue Authority (AADE) published Decision A. 1141 regarding the extension of filing deadline to 30 November 2022 for the annual certificate of tax compliance for corporations, Greek PEs of foreign companies, limited liability companies, and private companies.
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Hong Kong Relief from double taxation: On 28 October 2022, the Inland Revenue (Amendment) (Taxation on Specified Foreign-sourced Income) Bill 2022 was gazetted. According to the bill, if an MNE entity has specified foreign-sourced income chargeable to profits tax and has paid tax in a territory outside Hong Kong which is of substantially the same nature as profits tax, double taxation relief will be available regardless of whether that territory has entered into a comprehensive avoidance of double taxation arrangement (CDTA) with Hong Kong or not.
Credits-Foreign Tax Credits: For any similar tax payable on specified foreign-sourced income in a non-CDTA territory, unilateral tax credit will be provided to the MNE entity if it is a Hong Kong resident person. Any tax credit allowed will be set off against the profits tax payable in respect of the specified foreign-sourced income concerned.
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Submission of returns: On 19 October 2022, the Hong Kong Inland Revenue Department (IRD) issued a Circular Letter extending the lodgement of 2021/22 tax returns to 30 November 2022.
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Ireland Thin capitalization rules: Section 32 of Finance Bill 2022 introduces a number of minor technical amendments to the interest limitation rule, introduced in the Finance Act 2021, which completed Ireland’s transposition of the Anti-Tax Avoidance Directives (ATADs). The rule places a limit on deductible interest expenses of 30% of EBITDA for companies within the scope of the measure.
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Lithuania Late payments of tax due-Interest due: On 27 September 2022, the Lithuanian Ministry of Finance (MoF) published the Order No.1K-325 providing a reduced interest rate on deferred payment (tax loan agreements) of taxes and fines for administrative offenses. Usually, it is equal to 0.01% per day (~3.65% per year), the order provides that the interest rate is 0.00013699% per day (~0.05% per year) during the fourth quarter of 2022 beginning on 1 October 2022.
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Luxembourg Submission of returns: On 12 October 2020, Luxembourg’s Finance Minister presented the draft budget law 2023 to the Parliament. The deadline for filing tax returns will be postponed to December 31 of each year from 2023. The extension will apply to corporate tax returns, individual, and municipal business tax from the tax year 2022, and net wealth tax returns from the tax year 2023.
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Netherlands Payment of tax: The Netherlands has extended the provision for a one-off payment break for the repayment of deferred tax debts of Covid-19 pandemic period from up to 3 months to 6 months.
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Nigeria Incentives: On 19 October 2022, the Nigerian president signed the startup act 2022 which provides a labelled startup may be entitled to exemption from the payment of income tax or any other tax chargeable on its income or revenue for a period of three years and an additional two years if still within the period of a labelled startup. A labelled startup shall enjoy full deduction of any expenses on research and development which are wholly incurred in Nigeria and the restrictions placed by the Companies Income Tax Act shall not apply to a labelled startup.
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Norway Taxation of capital gains: On 6 October 2022, the National budget for 2023 was delivered including several tax proposals related to corporate taxation. The Budget proposed to increase the tax rate from 35.2% to 37.84% on dividends and capital gains effective from 6 October 2022 and uplift rate is reduced from 17.69 per cent to 12.4 per cent for the petroleum sector.
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Puerto Rico Submission of returns: On 27 September 2022, the Puerto Rico Treasury Department extended the tax returns deadline until 15 December 2022 to file any income tax return, or its extension request.
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UK Rates-National/ Federal: On 14 October 2022, the UK government announced that Corporation Tax will increase to 25% (currently 19%) from April 2023. The previously announced small profits rate of Corporation Tax will be maintained. Smaller or less profitable businesses will not pay the full 25% rate, and companies with less than £50,000 of profit – the large majority – will not see any increase at all, continuing to pay Corporation Tax at 19%.
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Zambia Rates-National/ Federal: On 30 September 2022, the Minister of Finance (MoF) proposed the 2023 Budget to the National Assembly. The important tax measures of the budget include the reduction of corporate income tax rate from 30% to 25% on income earned from value addition to gemstones through lapidary and jewelry facilities and replacing the two-tier taxation system in the telecommunication sub-sector (30%/40%) with a single tax rate of 35%.
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