Malaysia: IRBM issues revised guidance on bilateral, unilateral foreign tax credits
The Inland Revenue Board of Malaysia has issued Public Ruling No. 3/2026 on 22 May 2026, guiding the application of bilateral and unilateral tax credits where a Malaysian tax resident is subject to taxation in both Malaysia and a foreign
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US: JCT publishes detailed explanation of tax overhaul under One Big Beautiful Bill Act
The US Congress Joint Committee on Taxation (JCT) published, on 28 May 2026, its General Explanation of the Tax Provisions of Public Law 119-21, providing a detailed breakdown of the tax measures contained in the One Big Beautiful Bill Act. The
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Chile: SII updates rules on dividend tax credits for Chinese shareholders
The Chilean tax authority (SII) issued Letter Ruling No. 794 on 15 April 2026, addressing how Chilean companies should handle dividend withholding taxes when distributing profits to Chinese resident shareholders, particularly when the company has
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Italy: Government introduces tax credits to counter rising fuel costs
Italy’s Revenue Agency has introduced emergency tax relief measures to combat surging fuel prices, including temporary excise duty cuts and EUR 110 million in tax credits for transport and fishing sectors through Decree Law No. 33 on 18 March
See MoreUS: Senate passes bill to block Russia-related tax benefits
The US Senate unanimously approved the Honor Act (S.327) during the week of 9 March 2026. The legislation prevents American companies from claiming foreign tax credits or deductions on taxes paid to Russia. Introduced by Senators Catherine Cortez
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CJEU rules Belgium non-compliant for excluding foreign tax credits under ADAT CFC framework
The Court of Justice of the European Union (CJEU) delivered a judgment on 26 February 2026, examining how Belgium has transposed the Controlled Foreign Company (CFC) rules under the Anti-Tax Avoidance Directive (ATAD). The case centred on whether
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Chile: SII clarifies tax credit claim for foreign taxes paid
Chile's tax authority (SII) issued Letter Ruling No. 286 on 4 February 2026, clarifying the conditions under which taxpayers may claim a credit for foreign taxes paid. The ruling responds to a taxpayer request seeking both a foreign tax credit where
See MoreChile 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 treatyÂ
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
See MoreUS: 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)
See MoreHong 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
See MoreUS: 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
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