Colombia: DIAN issues ruling on tax treatment of stock dividends
Recently, the Colombian National Tax Authority (DIAN) published Ruling 014495 of 6 June 2019, which sets out tax of profits in shares or stock dividend. The ruling includes the following points: Article 30 of the Tax Code (TC) provide the
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 MoreUK: Summary of responses to consultation on the restriction on offset of capital losses
On 11 July 2019 the UK government published a summary of responses to the consultation on the restriction of carried forward capital losses, which was held between 29 October 2018 and 25 January 2019. Interested parties submitting responses
See MoreNetherlands: Consultation on tax group regime
The Finance Ministry of the Netherlands has announced the launch of a public consultation on the design of a new corporate tax group regime to replace the current fiscal unity regime. The consultation includes four possible
See MoreKenya simplifies the taxation of non-tax profits distributed as dividends
On 8 February 2019, the Kenya Revenue Authority (KRA) published a notice clarifying the new measure introduced by the Finance Act, 2018. The Act introduced a new corporate rate on untaxed gains or profits from which dividends are distributed with
See MoreFrance: Parliament legislates the Finance Act for 2019
The French Finance Act passed its constitutional review for 2019 on 28 December 2018. This follows the approval of the law by Parliament on 20 December 2018. The main measures of the law are summarized as follows: Corporate Income tax rate:
See MorePakistan: Finance Supplementary (Second Amendment) Bill submits in Parliament
On 23 January 2019, Pakistan’s draft Finance Supplementary (Second Amendment) Bill, 2019 was submitted to the National Assembly. The finance minister clarified that, "This is not a budget, this is a corrective package aimed at addressing various
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See MoreUK: Draft guidance on taxation of insurance companies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 MoreRomania permits quarterly dividend distributions
On 10 July 2018 the Romanian legislature passed Law no 163/2018 in the Official Gazette allowing quarterly dividend distributions.The Law amended the Accounting Law 1991 and the Companies Law 1990 to provide companies with the option to distribute
See MoreMalta amends participation exemption rules
On 29th March 2018, Malta has published the Budget Measures Implementation Act, 2018 (Act No. VII of 2018) in the Official Gazette. Some of the Key measures are introduced as the minimum holding percentage for the participation exemption for
See MoreUS: IRS issues additional guidance for computing the “transition tax” on foreign earnings
On 2 April 2018, the Treasury Department and the Internal Revenue Service published additional guidance (Notice 2018-26) for computing the “transition tax” on the untaxed foreign earnings of foreign subsidiaries of U.S. companies under the Tax
See MoreThe Swiss Federal Council approves tax proposal 17
The Swiss Federal Council has adopted the dispatch on TP17 for the attention of the Federal Assembly on 21st March 2018. It wishes to quickly to improve matters for domestic and foreign companies with the proposal, also on the basis of international
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 MoreAustralia: Closing tax consolidation loopholes
On 22 March 2018, the Australian Government’s commitment to ensure multinationals pay the right amount of tax in Australia continued with the passage through Parliament of the Treasury Laws Amendment (Income Tax Consolidation Integrity) Bill
See MoreSouth Africa updates taxation of foreign dividends guidance
On 22 March 2018, the Government of South Africa released an updated version of its draft interpretation note on the taxation of foreign dividends. The ratios applied in section 10B (3) to calculate the partial exemption applicable to foreign
See MoreBelgium introduces CFC rules and 100% participation exemption
The Belgian corporate income tax reform decreasing the corporate income tax rate to 25% by 2020 (29.58% in 2018 and 2019), also amended a number of measures to increase the attractiveness of Belgium as a holding jurisdiction. Specifically, the
See MoreRussia clarifies the deduction of losses incurred by consolidated group
On 9 March 2018, the Ministry of Finance (MoF) clarified the deduction of losses incurred by consolidated group members. Accordingly, the MoF stated that, under article 278.1(1) of the Tax Code (TC), the tax base of a consolidated group of taxpayers
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