Malta 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
See MoreRussia: 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
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