Ukraine issues controlled foreign companies (CFC) notification requirements
On 28 March 2024, the State Tax Service of Ukraine released a notice directed to companies and individuals residing in Ukraine, detailing their duty to report on controlled foreign companies. This notification outlines the requirement for
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France updates non-cooperative states and territories list
The French General Tax Code's list of non-cooperative States and territories (NCSTs) was updated via Decree on 16 February 2024 and published in the Official Journal on 17 February 2024. The list includes the following 16 states and territories:
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Sweden: MoF proposes updates to pillar 2 global minimum tax rules
On 19 March 2024, the Swedish Ministry of Finance (MoF) released proposed amendments to the Act on Additional Tax, aimed at incorporating the Pillar 2 global minimum tax as outlined in Council Directive (EU) 2022/2523. As per the proposal, a
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Ecuador: SRI updates list of tax haven jurisdiction
On 20 February 2024, the Ecuador Internal Revenue Service (SRI) amended Resolution No. NAC-DGERCGC15-00000052 through Resolution No. NAC-DGERCGC24-00000007. As per the amendment, the tax authority included the following countries and territories as
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Japan submits tax reform bill 2024 to parliament
On 2 February 2024, the Japanese Cabinet submitted the tax reform bill 2024 to parliament. The bill covers various tax measures. Key measures of the bill include: Driving Domestic Growth: The introduction of new tax credit incentives is
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Ukraine mandates reporting of controlled foreign companies (CFCs)
On 6 February 2024, the State Tax Service of Ukraine issued a release outlining the mandatory reporting of controlled foreign companies. The State Tax Service of Ukraine informs that the campaign for submission by controlling persons of Reports on
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Russia: FTS updates list of jurisdictions that do not exchange proper information for CFC purpose
On 10 January 2024, the Russian Federal Tax Service (FTS) published updated list of jurisdictions that do not exchange tax information with Russia (Decree No. ЕD-7-17/914). The list pertains to the tax exemption for profits of controlled foreign
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Belgium approves 2024 budget Introducing new CFC rules
Belgium has approved the 2024 budgetary measures, including new CFC rules, increased progressive tax on credit institutions, and strengthening Cayman tax rules. New CFC rules One key aspect of Belgiam’s CFC rules is the implementation of the
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Lithuania updates its blacklist in various tax aspects
On 30 November 2023, Lithuania issued an order revising its list of selected territories (blacklist), incorporating Russia as a new addition. The blacklist plays a crucial role in various tax aspects, including Lithuania's CFC rules. List of
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Germany updates tax haven defense ordinance: Adds and removes jurisdictions in response to EU decision
On 20 December 2023, Germany issued the Ordinance, amending the Tax Haven Defense Ordinance, as published in the Official Gazette. The Tax Haven Defense Ordinance plays a critical role in identifying jurisdictions considered non-cooperative under
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Italy: CFC rules related to GloBE pillar 2 amended to include 15% tax rate option and substitute tax
On 19 December 2023, Italy's Council of Ministers passed a legislative decree to enforce the tax reforms related to international taxation. This includes implementing the Pillar 2 global minimum tax under Council Directive (EU) 2022/2523 of 14
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Belgium proposes new draft law for CFC rules
The Belgian government has submitted a new draft bill to parliament for implementing stricter rules concerning the taxation of the undistributed income of a controlled foreign company (CFC), shifting from model B (targeting tax avoidance
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Germany: MOF issues draft guidance on anti-tax avoidance measures
On 30 November 2023, the German Ministry of Finance (MoF) issued draft guidance on anti-tax avoidance measures targeting non-cooperative jurisdictions. This follows the 2021 Tax Haven Defense Act, responding to EU guidelines against harmful tax
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Russia: FTS updates non cooperative Jurisdictions list for CFC purpose
On 14 November 2023, the Federal Tax Service (FTS) is in the process of updating its list of jurisdictions that do not meet Russia's standards for tax information exchange. The list of countries that do not cooperate with Russia on tax matters
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Russia: MOF publishes tax policy plans for 2024
On 2 November 2023, the Ministry of Finance in Russia released a statement regarding the tax policy proposals announced by State Secretary and Deputy Minister of Finance, Alexey Sazanov, during a recent event hosted by the B1 company. The statement
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Belgium: Federal Government agrees on budget measures for FY 2024
On 9 October 2023, the Belgian government agreed on Budget measures for the fiscal year 2024. Here is a broad summary of the key tax measures in the budget agreement, as announced by the finance minister. The proposed key measures are
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Russia amends regulations on taxation of controlled foreign companies
On 31 August 2023, the government of Russia announced new tax rules that will exempt profits of foreign collective investment structures from taxation. The exemption will apply if the following conditions are met: The profit of the structure is
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Germany: BMF publishes draft guidance on CFC legislation
On 20 July 2023, the Federal Ministry of Finance (BMF) issued draft guidance concerning the implementation of the Foreign Transactions Tax Act (FTTA), specifically addressing the taxation aspects related to controlled foreign corporations (CFCs).
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