Malta amends participation exemption rules

11 April, 2018

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

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US: IRS issues additional guidance for computing the “transition tax” on foreign earnings

10 April, 2018

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

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The Swiss Federal Council approves tax proposal 17

31 March, 2018

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

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Saudi Arabia: Ministerial Resolutions amends certain implementing articles of the By-law

27 March, 2018

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

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Australia: Closing tax consolidation loopholes

25 March, 2018

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

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South Africa updates taxation of foreign dividends guidance

24 March, 2018

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

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Belgium introduces CFC rules and 100% participation exemption

22 March, 2018

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

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Russia clarifies the deduction of losses incurred by consolidated group

10 March, 2018

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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Russia: MOF clarifies the application of the 0% rate to dividends

07 March, 2018

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

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Switzerland: Federal Council set the parameters for the dispatch on tax proposal 17

11 February, 2018

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

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Slovak Republic: President approves the Amendments to Income Tax Act

31 January, 2018

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

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Belgian Parliament enacts corporate tax reform

28 December, 2017

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

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Netherlands: MoF publishes an overview of tax changes for 2018

21 December, 2017

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

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Morocco: Parliament adopts draft Budget for 2018

14 December, 2017

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

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Greece: List of preferential tax regimes jurisdictions releases for 2016 and 2017

30 November, 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

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France: Government publishes draft second Amendment Financing Act for 2017

20 November, 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

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US: IRS issues a correction on tax regulations

20 November, 2017

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

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Belgium: Government approves draft law on corporate tax reform with fully participation exemption

14 November, 2017

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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