Nigeria: Implications of BEPS proposals
The Federal Inland Revenue Service (FIRS) has incorporated into its tax audit procedures certain of the recommendations included in the OECD’s base erosion and profit shifting (BEPS) project. For instance, the tax authority is scrutinizing
See MoreRussia: A draft order regarding tax exchange information published
The Federal Tax Service (FTS) has released a draft order on 26th October 2015 that contains a list (in Russian) of countries and territories which do not exchange tax information with Russia for discussion purposes. According to article 25.13-1 of
See MoreItaly: Published Legislative Decree to Implement Tax Measures
Italy has Published Legislative Decree No. 147 of 14 September 2015 to Implement Tax Measures. The following issues are the main corporate tax measures as per the Legislative Decree: As per article 3 of the Legislative Decree, Dividends directly
See MoreRussia: Federal Council accepts amendments on CFC rules
The Russian Federation Council has accepted draft law, No. 714002-6 on 3rd June 2015 that contains changes to the Controlled Foreign Company (CFC) rules and the tax residency idea. It was signed by the President and officially published on 8th June
See MoreChile: Circular 30 regarding administrative interpretation published
A Circular 30 of the tax administration (Servicio de Impuestos Internos, SII) about SII's administrative interpretation concerning amendments introduced by Law 20,780 to the Income Tax Law and specifically, it contains the new article 41 G on CFC
See MoreRussia: Law concerning notification process of CFCs adopted
The parliament has approved Law No. 667946-6 on 27th March 2015 for extending the deadline of tax resident’s notification about the involvements held in controlled foreign companies (CFCs). The deadline for notification has been extended from 1st
See MoreJapan: Tax Reform Plan 2015 Submitted to the Diet
The bills for the proposed changes to the tax law as announced on 30 December 2014 were submitted to the Diet on 17 February 2015. The main Proposal for changes is summarized below: Corporation taxation: The corporate tax rate is reduced for
See MoreRussia: Clarifications on computing taxable income of CFCs published
The Ministry of Finance (MoF) has released Letter No. 03-03-06/1/68300 describing the process to calculate the taxable income of controlled foreign companies (CFCs) for the purposes of taxation in Russia. The letter was issued on 29th December 2014.
See MoreRussia: Taxation of Controlled Foreign Companies and other anti-offshore measures
The amendments to the Tax Code on CFC, has focused on the following matters: Controlled foreign companies Beneficial ownership Tax residence determination by the company's management place Taxation of real estate transactions Criminal
See MoreRussia: Law providing CFC rules signed
The President of Russia has signed a Federal Law No. 376-FZ for introducing the CFC rules on 24th November 2014. The law enters into force with effect from 1st January
See MoreRussia: 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
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