Chile clarifies indirect foreign tax credit treatment for CFCs
Ruling No. 1500-2025 confirms that the indirect foreign tax credit applies only if a treaty or information exchange agreement exists and the CFC owns at least 10% of the subsidiary. Chile’s tax administration (SII) issued Ruling No. 1500-2025
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Chile clarifies foreign tax credit not covered by tax treaty
Chile’s tax authority (SII) has published Letter Ruling No. 369 on 14 February 2025 regarding foreign tax credits for taxes not covered by a treaty. The letter addresses whether a credit applies to US state taxes on income from technical
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US: Senate bill seeks to block tax credits and deductions for payments to Russia
US Senators Catherine Cortez Masto and John Cornyn have introduced bipartisan legislation on 30 January 2025 aimed at blocking businesses from claiming foreign tax credits or deductions for taxes paid to fund the Russian government's war
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Netherlands clarifies minimum tax to have little effect on incentives, cautions on new tax credits
The Netherlands State Secretary for Finance, in a letter to the parliament, stated that the global minimum tax would have limited effects on current tax incentives but highlighted that the newly introduced tax credits under Pillar Two could pose
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Taiwan issues guidance on foreign tax credit evidence requirements
The National Taxation Bureau of Taipei, Ministry of Finance, stated that for any profit-seeking enterprise having its head office within the territory of the China, profit-seeking enterprise income tax shall be levied on its total profit-seeking
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Hong Kong passes bill for amending the foreign-sourced income exemption regime
On 29 November 2023, the Legislative Council of Hong Kong announced the passage of the Inland Revenue (Amendment) (Taxation on Foreign-sourced Disposal Gains) Bill 2023. The Bill refines Hong Kong's foreign-sourced income exemption (FSIE) regime
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US: IRS issues practice unit on categorization of income and taxes into proper basket for FTC
On 15 May 2023, the U.S. IRS published a practice unit regarding Foreign Tax Credit - Categorization of Income and Taxes Into Proper Basket. This Practice Unit is revised to address changes from the implementation of the Tax Cuts and Jobs Act (TCJA)
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Hong Kong: IRD publishes updated guidance on foreign-sourced income exemption regime
On 23 December 2022, the Inland Revenue Department of Hong Kong has published updated guidance on the new Foreign-Sourced Income Exemption (FSIE) regime in the Official Gazette. The FSIE which is introduced by the Inland Revenue (Amendment)
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Hong Kong welcomes passage of bill on foreign-sourced income exemption regime
On 14 December 2022, the Hong Kong Legislative Council has passed the Inland Revenue (Amendment) (Taxation on Specified Foreign-sourced Income) Bill 2022. The bill introduces a new foreign-sourced income exemption (FSIE) regime for passive income
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US: IRS issues guidance related foreign tax credit
On 22 November 2022, the U.S. Internal Revenue Service issued a guidance relating to the foreign tax credit, including guidance with respect to the reattribution asset rule for purposes of allocating and apportioning foreign taxes, the cost recovery
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Hong Kong: IRD gazettes taxation on specified foreign-sourced Income bill 2022
The Inland Revenue (Amendment) (Taxation on Specified Foreign-sourced Income) Bill 2022 (the Amendment Bill) was gazetted on 28 October 2022 and was introduced into the Legislative Council on 2 November 2022 to provide a new framework for Hong
See MoreDominican Republic: DGII describes a guide on foreign tax credit
The Tax Authority has recently made a clarification through a guide, GLN 25641, regarding foreign tax credit (FTC) as well as unilateral relief methods. The following instructions are effective immediately and have included in the Tax Code: The
See MoreSingapore: MOF responses to public consultations on the draft ITA Bill 2021
On 3 September 2021, the Ministry of Finance (MOF) published its responses to feedback provided as part of the public consultation exercise conducted in connection with the draft Income Tax (Amendment) Bill 2021, which proposed a number of
See MoreColombia: Government submits tax reform bill to Congress after court ruling
On 22 October 2019, the Colombian Government submitted a new tax reform bill to Congress that will replace tax reform bill 2019 (Law No. 1943 of 2018). The tax reform bill 2019, which came into force on 1 January 2019, is invalid due to procedural
See MoreColombia legislates the tax reform Bill for 2019
Colombia enacted tax reform (Law 1943-Tax Reform) on 28 December 2018. The Tax Reform makes numerous changes to the Colombian tax rules that generally apply from 1 January 2019. The tax reform includes following changes: Corporate tax: The Tax
See MoreIndonesia approves new foreign tax credits rules
On 9 January 2019, Indonesia's Directorate General of Taxation published new regulation (No. 192/PMK.03/2018) regarding foreign tax credits. The new regulations update and replace prior regulations and generally apply in respect of foreign income
See MoreChina updates foreign tax credit rules
The State Administration of Taxation of China has published Circular 84 of 28 December 2017 regarding the determination of foreign tax credits. According to foreign tax credit rules, resident companies and permanent establishments of non-resident
See MoreUS: IRS issues revised guide on foreign tax credits (FTCs) for individual
The US Internal Revenue Service (IRS) has released a revised version of its tax guide on foreign tax credits (FTCs) for use by individuals when preparing their 2016 tax returns. The guide provides information on how to choose to take the FTC or the
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