On 23 April 2021, the Ministry of Taxation announced a public consultation for amending a draft Bill L 89. This Bill proposes for an Act amending the Corporation Tax Act and the Capital Gains Tax Act (Implementation of the minimum requirements of the Tax Avoidance Directive to the CFC rules of the Member States). The current draft amendment provides for a partial substance test in relation to the inclusion of other income from intangible assets as CFC income.
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Transfer Pricing Brief: May 2021
Transfer Pricing Brief: May 2021
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