Lithuania: VMI clarifies rules on foreign tax deductions
Lithuania’s State Tax Inspectorate (VMI) has updated its official commentary on the Law on Corporate Income Tax, clarifying how corporate income tax or an equivalent tax paid abroad can be deducted from Lithuanian corporate income tax. The
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Lithuania updates corporate tax guidance on CFC control, PE, group definitions
The Lithuanian State Tax Inspectorate (VMI) updated the commentary to the Law on Corporate Income Tax on 19 August 2026, with changes concerning several definitions under Article 2 of the Lithuanian Corporate Income Tax Law (PMÄ®). The guidance
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US: Treasury, IRS consults CFC election to simplify Section 987 foreign currency rules
The US Department of the Treasury and the IRS have initiated a public consultation regarding proposed regulations (REG-103844-26) allowing controlled foreign corporations (CFCs) to elect not to compute or recognise foreign currency gain or loss
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Lithuania: VMI clarifies CFC taxation rules in updated guidance
Lithuania’s State Tax Inspectorate (VMI) updated its guidance on the Law on Corporate Income Tax on 11 August 2026. The guidance details the official commentary and legal amendments regarding the taxation of positive income from controlled foreign
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Korea (Rep.) updates Pillar Two, CFC rules among other measures in 2026 Tax Reform Plan
Korea (Rep.)'s Ministry of Economy and Finance (MoEF) has unveiled its 2026 Tax Reform Plan, proposing a broad package of tax measures aimed at strengthening domestic manufacturing, supporting innovation, expanding tax relief for households and
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Taiwan reminds businesses of documentation requirements for CFC FVPL tax deferral election
Taiwan's Ministry of Finance, in a notice on 4 August 2026, has reminded enterprises that elect to defer the recognition of unrealized gains and losses from fair value through profit or loss (FVPL) financial instruments held by their Controlled
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Australia updates GloBE minimum tax provisions on CFC interaction, deferred tax assets, flow-through entities
Australia has issued the Taxation (Multinational—Global and Domestic Minimum Tax) Amendment (2026 Measures No. 2) Rules 2026 (the Amending Rules), introducing minor amendments to the Taxation (Multinational—Global and Domestic Minimum Tax) Rules
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Taiwan clarifies CFC exemption criteria under anti-avoidance rules
Taiwan’s National Taxation Bureau of the Northern Area (NTBNA) has reiterated, on 28 July 2026, the key exemption criteria under the country’s Controlled Foreign Company (CFC) regime, urging businesses to ensure compliance with the rules when
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Netherlands updates hybrid mismatch guidance with new rules on US tax regimes, permanent establishments
The Netherlands published the Hybrid Mismatch Policy Decision 2026 (Decree No. 2026-12123), issued by the State Secretary of Finance on 24 July 2026, replacing the previous policy decision that was originally issued in 2021 and subsequently updated
See MoreNetherlands: CFC levy cannot offset low-tax free investments under participation exemption
The Dutch Tax Administration issued a clarification on 21 July 2026, explaining that the controlled foreign company (CFC) levy does not take low-tax-free investments into account. The recent clarification by the Dutch Tax Administration provides
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European Commission releases final report on ATAD evaluation
The European Commission has published its final evaluation report on the Anti-Tax Avoidance Directive (ATAD) on 25 June 2026, covering the period from 1 January 2019 to mid-2025. The report assesses the effectiveness of ATAD in meeting its
See MoreTaiwan clarifies CFC loss deduction filing, documentation requirements
Taiwan’s National Taxation Bureau of Taipei, Ministry of Finance, stated that the Controlled Foreign Corporation (hereinafter referred to as CFC) system has been in effect since 2023. Profit-seeking enterprises reporting CFC's losses must provide
See MoreTaiwan: Businesses reminded to apply for CFC financial statement filing extensions
The Kaohsiung National Taxation Bureau of the Ministry of Finance announced on 25 May 2026 that, for any reason, those who are unable to submit their CFC financial statements within the prescribed period may apply to their local tax authority for an
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Taiwan: Tax bureau reminds firms of CFC financial statement filing deadline
Taiwan’s Northern Taiwan National Taxation Bureau of the Ministry of Finance announced that the filing period for the 2025 profit-seeking enterprise income tax return is from May 1 to May 31, 2026 (extended to June 1 if the deadline falls on a
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Taiwan clarifies CFC document extension rules for corporate tax filings
Taiwan’s Central District National Taxation Bureau of the Ministry of Finance clarified that profit-seeking enterprises required to report income from Controlled Foreign Corporations (CFCs) must disclose relevant information and attach supporting
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Canada tables bill introducing budget measures, includes amendments to Global Minimum Tax Act
Canada's Department of Finance has tabled the Notice of Ways and Means Motion to introduce a bill entitled A second Act to implement certain provisions of the budget in Parliament on 4 November 2025. The bill introduces a range of measures,
See MoreTaiwan tightens 2023 CFC audits, flags misreported income breaching de minimis threshold
Taiwan’s National Taxation Bureau of the Northern Area, MOF, stated, on 30 April 2026, that it has strengthened audits of Controlled Foreign Corporation (CFC) cases for the year 2023 on profit-seeking enterprise income tax filings within its
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Montenegro proposes draft corporate tax rules in accordance to EU ATAD
The Government of Montenegro has released a draft law on Amendments to the Law on Corporate Income Tax, proposing measures to address profit shifting in accordance with the EU Anti-Tax Avoidance Directive (ATAD) (Directive 2016/1164 as amended by
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