Finland: Ministry of Finance issues a draft bill proposing amendments to the CFC rules.
On 6 August 2018, the Finnish MoF published a draft consultation on a draft law that proposed changes to the Finnish CFC rules. The draft law aims to implement the CFC provisions contained in the EU ATAD. The bill would introduce changes to the CFC
See MoreCroatia: MoF publishes a draft bill covering various sectors
The Finance Minister, Zdravko Marić, on August 16, 2018, published draft bill on amendments to the Law on administrative cooperation in tax matters. This Act shall enter into force on the eighth day after its publication in the Official Gazette
See MoreAustria: Parliament adopts the annual Tax Act 2018
On 11 July 2018, the Federal Council of Austria adopted the text of the Annual Tax Act 2018 as approved by the National Council (lower house) on 4 July. The legislation includes simplifications of tax laws, the abolishment of various fees and
See MoreRussia: Parliament considering the Bill amending CFC and other rules
Recently, the Russian lower house of parliament considering the Bill No. 442400-7, which includes various measures. The Bill includes following measures: 1. Adjust the CFC rules so that a person will not be recognized as a controlling person of a
See MoreBrazil clarifies CFC rule regarding exemption for oil and natural gas industry
Private Ruling 4,020/2018 concerning the exemption under CFC rules for profits acquire by the oil and gas industry was published in the Official Gazette on 19th June 2018. The Decision clarifies that the tax exemption of the profits realized is
See MoreLuxembourg: Government submits EU Anti-Tax Avoidance Directive (ATAD) to Parliament
On 20 June 2018, the draft law (Draft Law) implementing the European Union (EU) Anti-Tax Avoidance Directive (ATAD) was introduced in the Luxembourg Parliament. Accordingly, as from 2019, a new provision will be introduced that limits interest
See MoreLuxembourg: Cabinet approves draft law for implementation of EU anti-tax avoidance directive
On 15 June 2018, the Luxembourg Cabinet approved a draft bill providing for measures to implement the EU Anti-Tax Avoidance Directive (ATAD). The draft bill includes the new provisions on the limitation of interest deduction, which limit the
See MorePakistan enacts Finance Bill 2018
The Finance Bill, 2018 was passed by the government on 22 May 2018, with some amendments. The Bill provides for the implementation of the measures proposed as part of the 2018-2019 Budget. The main measures are summarized as follows: Corporate
See MoreAustralia updates international dealings schedule for 2018 tax year
The Australian Taxation Office (ATO) has released the 2018 International dealings schedule (IDS) and their instructions for 2018 tax years. The IDS must be lodged by businesses that provide a response at the trigger questions of the relevant
See MorePakistan: Finance Minister presents the budget for 2017/2018
On 27 April 2018, the newly-appointed Finance Minister Miftah Ismail presented the 2018/2019 Budget to parliament. The following corporate tax measures are proposed in the Budget: Reduction in corporate tax rates: Reduce the corporate tax rates
See MoreColombia 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
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