Russia: CFC law has been adopted by the Federal Council
The Federal Council has adopted the draft law on 19th November 2014 that initiates the CFC rules. There is no significant change in the adopted law compared to the previous draft. This law will enter into force with effect from 1st January
See MoreRussian Parliament to Consider Revised Draft of CFC Law
On 22 October 2014 the Russian parliament received a new version of the draft law on controlled foreign companies (CFCs). Parliamentary hearings on the latest draft law are to take place on 11 November 2014. Generally the draft law aims to
See MoreBrazil: Amendments on Controlled Foreign Corporations (CFC) Rules
A deemed tax credit of 9% under CFC rules for Brazilian companies with foreign investment in some predefined industrial sector has been extended by a recent guidance. The deemed tax credit results in the lower taxation of profits earned abroad by
See MoreRussia: Revised version of the draft law publishes
The Ministry of Finance in Russia has released a significantly revised version of the draft law on the package of tax initiatives on September 2, 2014. This contains a number of significant changes affecting such matters as exclusions from
See MoreRussia: Revised draft changes related to introduction of CFC rules
The Ministry of Finance has released a revised version of the draft law regarding introduction of CFC rules. The important changes of the revised draft law are given below: • Concepts regarding “Beneficial owner” and “actual right to receive
See MorePoland: Proposals for CFC regime
Poland proposed bills to changes to its controlled foreign corporation (CFC) rules and thin capitalization regime. According to the rules tax would be levied on specific income which obtained from some foreign subsidiaries owned by the taxpayers of
See MoreNew Russian CFC and anti-avoidance legislation
The amended draft law regarding controlled foreign companies and other anti-offshore measures has done most valuable changes in the field of foreign tax structures and tax avoidance. This law has publicly available on 27 May, 2014. It highlights
See MoreUnited Kingdom: Dispute resolution, CFC financing, investment “white list”
HM Revenue & Customs have updated some key documents regarding resolution of tax disputes, and have provided new guidance on CFCs. The dispute resolution documents are the Code of Governance for resolving tax disputes; and Commentary on the
See MoreBrazil Provisional Measure 6272013 – CFC rules for resident individuals introduced
On 4 December 2013 it has been published that the Provisional Measure 627/2013 (PM 627/2013), introduced important changes to the Brazilian tax legislation. This was published in the Official Gazette of 12 November 2013. Among those changes, PM
See MoreNew CFC Rules Released in UK
The UK government has published its proposals for the reform of the Controlled Foreign Company (CFC) regime through a press release on 4 July 2011. The government intends to modernize the CFC regime in 2012, which it expects will better reflect the
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