Slovak Republic: Government declares new corporate tax measures
The Government announced several changes in the corporate taxation area on 20th June 2017, including the introduction of a new patent box regime in line with the modified nexus approach developed as part of BEPS Action 5. The government also
See MoreTaiwan: Draft amendment to controlled foreign company rules issued
Taiwan’s Ministry of Finance issued Ruling No. 10604557490 on 6 June 2017, providing clarification to the proposed controlled foreign company (CFC) regulations which was issued on 9 November 2016. According to the proposed CFC rules, Taiwanese
See MoreColombia: Tax reform 2016 amends, new CFC rules
On 5 June 2017, the government of Colombia published Decree 939 of 2017 that removed previous errors of articles 89, 99, 111, 123, 165, 180, 281, 289, 305, 317 and 319 of Law 1819 of 2016. In accordance with Law 1819, there are multiple provisions
See MoreCzech Republic: MoF issues a paper on anti-tax avoidance rules
The Finance Ministry published on its website a discussion paper regarding the implementation of EU Anti-Tax Avoidance Directive on 12th of July 2016. The directive mainly states new rules for interest deduction restrictions and similar expenses
See MoreBrazilian CFC rules apply despite treaties
The Federal Administrative Council of Tax Appeals (Conselho Administrativo de Recursos Fiscais, CARF) decided on 14 March 2017 that taxation in Brazil of profits of indirect controlled foreign companies (CFCs) under CFC rules is not prevented by tax
See MoreRussia: Clarifies the taxation of CFC profits in determining the corporate tax base of a consolidated tax group
The Ministry of Finance (MoF) on 3 March 2017, published Guidance Letter No. 03-12-11/3/5790 of 3 February 2017, clarifying the taxation of CFC profits in determining the corporate tax base of a consolidated tax group (CTG). According to article
See MoreRussia: Clarifications on carry-forward of CFC losses
The Ministry of Finance (MoF) issued Guidance Letter No. 03-04-05/5577(2 February 2017), clarifying the issue of losses incurred by a controlled foreign company (CFC) on 7 March 2017. The Ministry of Finance identified that, under Article 25.15,
See MoreColombia: Tax reform summary 2016
According to law 1819 of 2016, adopting the structural tax reform bill approved on 23 December 2016. It introduces the following major changes to the corporate income tax regime: Income tax rates As from tax year 2019, a single income tax rate of
See MoreBulgaria: 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
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