The Finance Department has published a draft legislative proposal to implement certain exceptional measures actually declared in the 2014 federal budget. The proposals contained 105 pages of draft legislation and 128 pages of explanatory notes, regarding thin-capitalization changes, withholding tax measures pointing certain loan arrangements and donation tax credits for estates. This also re-introduces tax procedures that were first published in August 2013 relating to the foreign affiliate dumping rules and introduces tax measures related to the definition of non-qualifying income in the foreign affiliate rules. Along with the proposed measures are provisions that would expand the rest of the anti-avoidance rules in the thin-capitalization provisions and to attach a loan provision into Part XIII.
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