UAE: FTA publishes corporate tax guide on exempt income
On 16 October 2023, the Federal Tax Authority (FTA) of the United Arab Emirates (UAE) released the Corporate Tax Guide on Exempt Income: Dividends and Participation Exemption. This guide is designed to provide general guidance to Taxable Persons,
See MoreSpain publishes state budget bill for fiscal year 2021
On 31 December 2020, Spain’s State Budget Bill for Fiscal Year (FY) 2021 (the Budget Bill) was published in the Spanish Official Gazette after its prior approval by the Spanish Congress and Senate. The main corporate tax measures are summarized
See MoreGreece: AADE publishes preferential tax regime status for the 2019
On 7 December 2020, the Greek Public Revenue Authority (AADE) published Circular No. A.1267 of 7 December 2020, which determines the states that have a preferential tax regime based on the provisions of par. 6 and 7 of article 65 of law 4172/2013
See MoreGreece: Government publishes Law 4646/2019 in the Government Gazette
On 12 December 2019, the President announced that Law 4646/2019 was published in Government Gazette. Corporate tax According to Law, as from 1 January 2020, corporate tax rate will be reduced from 28% to 24% for all legal entities for the
See MoreGreece: Parliament adopts tax reform measures
On 6th December 2019, Greek Parliament approved tax reform bill (Law 4646/2019), which contains several measures regarding corporate income tax, personal income tax, withholding tax rates, the participation exemption for capital gains
See MoreColombia: 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 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 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 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: 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 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 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 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 MoreNorway: Exemption from withholding tax applies
The tax authorities released a "binding advance ruling" (BFU / 17, 4 May 2017) regarding application of a domestic exemption from dividends to an Irish holding company. The judgment provides that the dividends paid by the Norwegian company to the
See MoreNetherlands: Updated decree publishes on implication of participation exemption
Decree No. BLKB2016/803M dated 20 January 2017 has been published in Official Gazette No. 5003 on 23 February 2017 regarding implication of the exemption from the participation. The Decree updated and replaced the Decree No. DGB2010/2154M of 12 July
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