Bulgaria: Updated list of tax havens published
The Finance Ministry has published an Order No. ZMF-1303 on 21st December 2016 regarding an updated tax haven list. This list applies from 29th December 2016 contains the following countries: Antigua and Barbuda, the Bahamas, Brunei, Christmas
See MoreTaiwan: Finance Minister publishes draft rules on CFC and PEM
Finance Minister issued draft regulations on a controlled foreign company (CFC) and place of effective management commenced in July 2016 on 9 November 2016. The draft regulations intend to explain CFC income’s timing and amount addition CFC
See MoreJapan: Amendments coming for CFC rules in 2017 tax reform
Japan's tax commission has announced on 8 December 2016, its intention to amend the tax rules regulating CFCs (controlled foreign corporations), which are also known as the Anti-Tax Haven Rules. According to the proposed 2017 tax reform, the
See MoreBrazil: Updates fictitious credit for CFC rule
Normative Instruction 1,674/2016 released in the official Gazette on 29 November 2016 and in force on the same date of publishing. Normative Instruction 1,674/2016 adjusts the option that, resident companies to submit the profits derived by the
See MoreColombia: Tax reform bill 2016
The comprehensive tax reform bill 2016 recently submitted by the government of Colombia to the Congress with the following corporate income tax issues: Rates: The bill proposes to unify the income tax and the Fairness Tax into a single income tax
See MoreItaly: Publishes new guidance on CFC regulations
The Italian Tax Authorities issued Protocol No. 143239 (the Protocol) on 16 September 2016, providing further clarifications on CFC legislation, as recently amended by Legislative Decree No. 147 of 14 September 2015 and Law No. 208 of 28 December
See MoreBrazil: Decision releases concerning the application of the new Brazilian CFC rules
The Federal Court of Curitiba passed on a decision in relation to Process No. 5005596- 52.2015.4.04.7000/PR on May 6, 2016.The single court judgments finish off that a Brazilian taxpayer may remove from the calculation of its corporate income tax
See MoreRussia: Notification of tax authorities concerning CFCs
The Finance Ministry (MoF) has issued a Letter No. 03-01-23/30779 on 27th May 2016 for clarifying the responsibility of taxpayers to notify the tax authorities about CFCs. On the basis of section 3.1 of article 23 of the Tax Code, taxpayers have to
See MoreChile: IRS publishes final instructions on 2014 Tax Reform and 2015 Simplification Law
The Internal Revenue Service (IRS) of Chile has published the last set of Circulars (Circular no. 40, 41, 42, 44, 48 and 49) along with instructions on the amendments introduced by the 2015 Simplification Law (Law 20,899) on 13th and 14th July 2016.
See MoreTaiwan : Implements CFC, place of effective management concepts
Taiwan’s Legislative Yuan amended the Income Tax Act (ITA) on 12 July 2016, and introduced the controlled foreign company (CFC) rules, incorporating some of the recommendations provided in the Organization for Economic Co-operation and
See MoreEU agrees on draft Directive on anti-avoidance
On 21 June 2016 the EU’s Economic and Financial Affairs Council reached agreement on a draft Directive on tax avoidance practices following expiry of the required period for further issues to be raised. The draft Directive will be presented for
See MoreRussia: Draft Order for approving CFC notification form published
According to the Russian Tax Code, individuals and companies are needed to notify the tax authority of controlled foreign companies (CFC) of which they are considered controlling persons. Note that, these companies and individuals are considered to
See MoreRussia: List of documents substantiating exemption of CFC profits
The Federal Tax Service (FTS) has published a Letter No. ED-3-13/1427 on 4th April 2016 for describing the time limits for submission to the tax authorities of notifications on controlled foreign companies (CFCs) and the necessary documents
See MoreRussia: Amendments to CFC rules entered into force
The president of Russia has signed Federal Law No. 32-FZ on February 15, 2016 that amends the СFC provisions. This Law has published on 15th February 2016 and will enter into force on 1st January 2017. For bank loans that will already be exempt
See MoreRussia: Amendments to CFC rules adopted by lower chamber
The lower chamber of the parliament has passed in the third reading the draft Federal Law No. 724609-6 amending the thin capitalization rules on 29th January 2016, which was submitted to the lower chamber of the parliament on 14th December 2015. It
See MoreNigeria: Country-by-country reporting update
A Multilateral Competent Authority Agreement (MCAA) has been signed by Nigeria for executing the exchange of country-by-country (CbC) reports. This reports will include summary of income earned and tax paid, and the number of employees positioned by
See MoreChile: Details of administrative interpretation on CFC rules disclosed
The Circular 30 of the tax administration has been effected from January 1, 2016. It was published in the official gazette on May 14, 2015. The main features of the CFC rules are as follows: A controlled foreign entity exists where a Chilean
See MoreRussia: Draft amendments to CFC rules
A draft of Federal Law No. 953192-6 regarding the СFC provisions was submitted to the lower chamber of the parliament on 14th December 2015. The CFC provisions were first provided by the Tax Code and Federal Law No. 376-FZ of 24 November 2014. The
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