On 12 November 2019, a proposal to changes the Corporation Tax Act was submitted to Parliament. The law proposed the following measures:

  • propose to amendments the thin capitalization rules in order to increase the level of expenditure that is not considered as interest expense for the application the rules;
  • propose to amend the CFC rules, specifies the criteria for determining the persons to whom these rules apply;
  • propose not to recognize the accounting expenses related to payments for hybrid mismatches for corporate income tax purposes; and
  • Propose that the deferral of payment of corporate income tax in the context of exit taxation is possible only when the transfer of assets and/or activities is incidental or irregular.