US: final regulations on carryback of consolidated net operating losses
On 12 July 2023, the U.S. Treasury Department and IRS released final regulations in the federal register that affect corporations filing consolidated returns. These regulations permit consolidated groups that acquire new members that were members
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Malta amends the income tax group deduction rules
On 21 February 2023, Malta published Legal Notice 40 of 2023 in the Official Gazette amending the income tax group deduction rules. According to the amendments, the total allowable deductions that may be claimed shall not exceed EUR 1 million per
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South Korea: MOEF announce tax reform plan for 2022
On 21 July 2022, South Korea’s Ministry of Economy and Finance (MOEF) announced the tax reform plans for 2022. The aim of this plan is to enhance corporate competitiveness, reinforcement of tax support for jobs and investment, support smooth
See MorePoland publishes law amending corporate income tax act
On 30 November 2020, the act amending the Corporate Income Tax Act was published in the Polish Journal of Laws and thus entered into force. The amendment introduces compliance of limited partnership having their management or registered office in
See MoreIndia legislates Finance (No. 2) Act 2019
On 1 August 2019, India has published the Finance (No. 2) Act 2019 in the Official Gazette, which was approved by the president. The measures of the Act are in line with those presented as part of the Union Budget for 2019-20. Corporate tax
See MoreMalaysia: Parliament passes Finance bill 2018 (Budget 2019)
On 10 December 2018, the House of Representatives passed the Finance Bill 2018 which was published in the Federal Gazette on 27 December 2018. The key changes of Finance Bill 2018 are summarized below: Corporate Tax Changes The limitation
See MoreUK: Draft guidance on taxation of insurance companies
On 13 December 2018 HMRC issued for consultation draft guidance on the corporation tax treatment of insurance companies writing life insurance and other long term insurance business. The Life Assurance Manual is primarily written for HMRC staff
See MoreSaudi Arabia: Ministerial Resolutions amends certain implementing articles of the By-law
The Ministerial Resolution No. 1727 dated 11 February 2018 has amended the following key articles of the By-Law: General provisions- Article 1: Persons subject to taxation include resident capital companies with respect to shares owned directly or
See MoreMorocco: Parliament adopts draft Budget for 2018
The Ministry of Economy and Finance of Morocco was announced on December 13, 2017 that the parliament adopted the draft Finance Law for 2018. The draft budget 2018 was presented to the Parliament on October 20, 2017. So, the draft measures will
See MoreMorocco: Draft Budget for 2018
The draft budget 2018 was presented to the Parliament on October 20, 2017. This draft Law is available in French language. The Economic and Finance Minister, Mr. Mohamed Boussaid, held a press conference regarding the Finance Bill 2018 on October
See MoreHong Kong adopts a new intragroup tax loss transfer regime
According a proposal from high level government advisory panel, Hong Kong adopts a new intragroup tax loss transfer regime. If adopted, these new tax rules would have significant impact on business and investment decision-making in Hong Kong,
See MoreUK: Main 2017 tax changes affecting corporation tax
The budget insert for the CT600 company tax return, initially issued in March 2017, has been updated to include further information on changes affecting the return. The changes cover announcements made in the 2016 Autumn Statement and measures in
See MoreUK: Timetable for Finance Bill (No. 2) 2017
According to an announcement of 20 July 2017 in Hansard the Ways and Means Resolutions relating to the Finance Bill (No. 2) 2017 are to be submitted to the House of Commons for approval on 6 September 2017. The Bill is expected to be published
See MoreRussia: Clarifications on carry-forward of CFC losses
The Ministry of Finance (MoF) issued Guidance Letter No. 03-04-05/5577(2 February 2017), clarifying the issue of losses incurred by a controlled foreign company (CFC) on 7 March 2017. The Ministry of Finance identified that, under Article 25.15,
See MoreVietnam: Issues new Circular on Corporate Income Tax
The Ministry of Finance published Circular No. 78/2014/T-BTC (Circular No. 78) on 18 June 2014, which provides additional execution guidance in respect of Decree No. 218/2013/ND-CP (Decree No. 218) which was issued on 26 December 2013. Decree 218,
See MoreUnited Kingdom – Supreme Court addresses cross-border group losses
The UK Supreme Court on 19 February 2014 issued its judgment relating to three remaining issues in the Marks & Spencer case—i.e., the case addressing a cross-border group relief claims. The Court found that the conditions for the “no
See MoreECJ: Decision on state aid and Finland’s tax loss carry forward rules
A case was brought before the European Court of Justice (ECJ) concerning the question of whether Finland’s rules for carrying forward tax losses were contrary to the state aid provisions in Article 107 of the Treaty on the Functioning of the
See MoreECJ: European Commission refers the matter of cross-border loss relief for UK groups
The European Commission has requested the European Court of Justice (ECJ) to determine that the conditions imposed by the UK tax rules on cross-border group relief mean that in practice it is almost impossible for companies to receive this loss
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