On 9 August 2018, the Ministry of Finance officially submitted its budget proposal for next year 2019. The budget introduced changes to the CFC definition and applicable exemptions, including reducing the control threshold for a company that qualifies as a CFC from the current 50% (direct or indirect ownership) to 25% of ownership of share capital or voting rights or profit entitlements as defined by ATAD(Anti-Tax Avoidance Directive). The new rules would enter into force on 1 January 2019 and be applied for the first time in relation to the taxation of 2019.
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