Russia: MOF clarifies the application of the 0% rate to dividends
In March 2018, the Ministry of Finance (MoF) clarified the application of the 0% (CIT) rate to dividends received by a company in reorganization. According to article 284(3.1) of the Tax Code, a tax rate of 0% is applied to dividends received by a
See MoreSwitzerland: Federal Council set the parameters for the dispatch on tax proposal 17
The Swiss Federal Council announced that it has set the parameters for the dispatch on the country's tax reform proposal (tax proposal 17) on 31st January 2018. The Federal Council's parameters that will be contained in the dispatch on tax proposal
See MoreSlovak Republic: President approves the Amendments to Income Tax Act
The amendment to Act No. 595/2003 Coll. on Income Tax has signed by the president on 20 December 2017. Most of the amendments entered into force from 1 January 2018. The main changes are summarized here: Definition of permanent establishment The
See MoreBelgian Parliament enacts corporate tax reform
On 22 December 2017, the Belgian Parliament approved the major corporate tax reform that announced in 26 July 2017. The main proposal was related to gradually reduction of corporate income tax rate. Currently, the normal rate is 33.99% and this will
See MoreNetherlands: MoF publishes an overview of tax changes for 2018
The Ministry of Finance (MoF) provides an overview of the most important tax changes as of January 1, 2018, which were approved by parliament on 19th December 2017. It concerns changes in the field of income tax, payroll tax, gift and inheritance
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 MoreGreece: List of preferential tax regimes jurisdictions releases for 2016 and 2017
A Circular No. 1173 of 10 November 2017 was published, which lists the jurisdictions considered to have the current situation of preferential tax for the tax years 2016 and 2017. This list covers the participation exemption, expenses deduction
See MoreFrance: Government publishes draft second Amendment Financing Act for 2017
On 15 November 2017, a second draft amending Finance Bill for 2017 was submitted to the French Council of Ministers and was submitted to the French Parliament. The draft law emphasized the following tax measures for the coming year. Anti-Evasion
See MoreUS: IRS issues a correction on tax regulations
The US Tax Administration (IRS) issued a correction to tax ordinances (TD 9803) on November 15 regarding the transfer of ownership of foreign corporations. These rules, which were published on 16 December 2016, retrospectively removed the exemption
See MoreBelgium: Government approves draft law on corporate tax reform with fully participation exemption
On 27 October 2017, according to a press release, on the proposal of the Minister of Finance, the government has approved the corporate tax reform. The corporate tax reform process would take place in two phases, 2018 and 2020. Belgium will grant
See MoreGermany: Capital gains 100% tax-exempt for foreign corporate shareholders
On 25 October 2017, the German Federal Tax Court (decision dated 31 May 2017) ruled in favor of foreign shareholders selling shares in a German corporation. Capital gains realized upon sale of shares in a German resident corporation by non-resident
See MoreDutch government contingency plans to restrict domestic tax consolidation
On 25 October 2017 the Dutch government announced emergency measures to prevent the Dutch tax consolidation rules being used in international tax avoidance structures. The measures are a direct response to ongoing litigation before the EU Court of
See MoreUS: Tax reform bill published
The long awaited US tax reform bill was released by House Republicans on 3 November 2017. The impact on the deficit is estimated at $1.5tn over 10 years. The corporate tax rate would be reduced from the current 35% down to just 20% starting in 2018.
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 MoreSaudi Arabia: Royal Decree on amendment to the Income tax law issued
The government of Saudi Arabia issued Royal Decree No. M/131 on 20 September 2017 modifying certain articles of the Income Tax Law (ITL). The most important amendments brought by the Royal Decree are as follows: -Shares in domestic corporations held
See MoreFrance: Draft finance bill for 2018 released
The government of France released the draft Finance Bill for 2018 on 27 September 2017. The main changes outlined in the draft Bill are as follows: Decrease of the French corporate income tax rate Elimination of the 3% tax on dividend
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 MoreAustralia: Consultation on Consolidation Integrity Measures
On 11 September 2017, the Minister for Revenue and Financial Services released draft tax consolidation legislation and an explanatory memorandum for public consultation. These important measures restore integrity to the tax consolidation rules. The
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