Colombia issues ruling of CFC exemption
The tax authority of Colombia (DIAN) published a ruling regarding whether the exemption for controlled foreign company (CFC) dividend income paid out of profits from real economic activities will apply if the dividends are paid by a subsidiary of a
See MoreAustria: MOF publishes a draft bill for 2018
On 9 April 2018, the Ministry of Finance (MOF) provided a draft bill for an Annual Tax Act 2018 and submitted it for final consideration. With this draft, the EU Anti-Tax Avoidance Directive (ATAD) will be implemented in Austrian domestic law and in
See MoreSouth Africa: SARS extends CFCs reporting rules to June
Recently, the South African Revenue Service has declared that it will temporarily allow taxpayers to report information on controlled foreign companies (CFCs) under the old filing rules, which were replaced in February From 1 June 2018 all taxpayers
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 MoreSouth Africa: Revenue services announces for temporary use of old filing rules
The South African Revenue Service will temporarily permit taxpayers to report information on controlled foreign corporations (CFCs) under the old filing rules replaced in February. SARS replaced the old reporting schedule in February, which was
See MoreNetherlands: Dutch Council of Ministers approves fiscal policy agenda
The Council of Ministers approved the fiscal policy agenda on a package to combat tax avoidance and tax evasion. The most important changes are summarized below: Corporate Income Tax (CIT) rate: According to the Agenda, the current standard Dutch
See MoreRussia: MoF clarification on application of thin capitalization rules in the context of tax treaties
Recently, the Ministry of Finance (MoF) issued a Guidance Letter (No. 03-03-06/1/87340) and clarified the application of domestic thin capitalization rules in the context of tax treaties. According to a statement by the MoF, interest paid by a
See MoreCzech Republic: Proposed amendments to income tax for 2019
Recently, Finance Ministry has published the first draft copy of the amendment to the Income Tax Act for comments. These amendments are supposed to be started from year 2019. The proposed personal income tax rate of 19% is 1.1% less than the present
See MoreUS: President signs Tax Cuts and Jobs Act
Congress has passed the Tax Cuts and Jobs Act(the Act), and the President signed it on December 22, 2017. The most important changes in the area of corporate taxation are: Main corporate tax rate: Under the new Act, the corporate tax rate
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 MoreKazakhstan: Tax Law Reforms for the year 2018
The Kazakh President, signed a series of laws on 25 December 2017 regarding taxes and other mandatory payments, introduction of tax code, law on amendments to other Acts etc. Most provisions of the new tax code and the tax amendments effects from 1
See MoreArgentina: Comprehensive tax reform enacts
The Law No. 27430 or comprehensive tax reform was published on December 29, 2017 in the Official Gazette and it generally applies from January 1, 2018. This comprehensive tax reform bill has sent to Congress on December 14, 2017. The Ministry of the
See MoreChile: Tax authority publishes list of Jurisdictions with preferential tax regime
The Internal Revenue Service (Servicio de Impuestos Internos - SII) of Chile published a Resolution No. 124 of December 19, 2017 regarding list of jurisdictions that are considered to have a preferential tax regime or zero or low taxation. The list
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 MorePoland publishes corporate income tax reform bill for 2018
On 27 November 2017, the Budget Bill for 2018 was approved by the parliament. The bill particularly amending the Polish Corporate Tax Act which published in the Official Journal. According to the bill the changes will enter into force on 1st
See MoreRomania: Ordinance amending the Tax Code published
In the Official Gazette no. 885 of 10 November 2017, Emergency Ordinance no. 79 concerning the modification and completion of Law no. 227/2015 regarding the Tax Code has been published by the Romanian Government. According to the new rule a taxpayer
See MoreTaiwan: The Ministry of Finance publishes the CFC implementation rules
The Ministry of Finance has announced the implementation of CFC (controlled foreign company) rules on September 20, 2017. The main features of the CFC rules are summarized below: CFC definitions: Under the rules, a foreign company located in a
See MoreEl Salvador: Tax authority issues tax havens list for 2018
The Tax Administration of El Salvador issued an annual guide (Resolution No. DG-001/2017) on 28 September 2017. The guidelines set out a revised list of countries, states or territories that are considered to be preferential tax regimes, low or
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