US: IRS publishes practice units on interest expense limitations
On 16 May 2023, the IRS Large Business and International (LB&I) division issued two practice units in relation to interest expense limitations for related party loans. Interest Expense Limitation on Related Foreign Party Loans Under IRC
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Brazil publishes law extending certain CFC benefits
On 13 April 2023, Law No. 14.547 transposing Provisional Measure 1148/2022 into law was published in the Brazilian Official Gazette, which extends certain benefits in regard to the controlled foreign company (CFC) rules under Law 12,973/14. Under
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Czech Republic revises Non-Cooperative jurisdictions list for CFC Rules
On 24 February 2023, the Czech Republic released Financial Bulletin No. 3/2023, that announced the non-cooperative jurisdictions list for the Czech Republic's controlled foreign company (CFC) regulations. The list has been updated in accordance with
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OECD: Technical Guidance for Implementation of the Global Minimum Tax
On 2 February 2023 the Inclusive Framework released technical guidance on implementation by governments of the global minimum tax. The Agreed Administrative Guidance for the Pillar Two GloBE Rules aims to ensure co-ordinated outcomes and greater tax
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Singapore: IRAS releases guidance on tax treatment of gains or losses from the sale of foreign assets
On 8 December 2023, the Inland Revenue Authority of Singapore (IRAS) released an updated e-tax guide on the tax treatment of gains or losses from the sale of foreign assets under the recently introduced Section 10(L) of the Income Tax Act (ITA).
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Taiwan provides the list of low-tax jurisdictions under CFC rules
On 13 December 2022, the Ministry of Finance of Taiwan issued a press release providing the list of low-tax jurisdictions under controlled foreign company (CFC) rules. The CFC rules will be effective from 1 January 2023 for profit-making enterprises
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Russia updates non cooperative Jurisdictions list for CFC purpose
On 5 December 2022, the Federal Tax Service of Russia published Order No. ED-7-17/987 in the Official Gazette which provides an update list of jurisdictions that do not have acceptable tax information exchange with Russia. The list applies in
See MoreUkraine: STS explains international taxation during martial law
On 3 August 2022, the State Tax Service (STS) of Ukraine explained the rights and obligations of taxpayers and supervisory authorities in matters of international taxation during martial law, taking into account the Ukraine- Russia war. Statute
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Poland: MoF proposes important amendments to corporate income tax law
On 28 June 2022, the Polish government announced a draft law to proposing significant changes to the Polish Corporate Income Tax Act. The proposed changes impact the following areas; The effective date of the new “minimum tax” will be
See MoreLuxembourg: Tax Authority updates guidance on CFC rules
On 17 June 2022, the Luxembourg Tax Authority published Circular n°164ter/1 (the guidance) on the controlled foreign corporation (CFC) rules. The guidance includes the following topics: Foreign controlled companies with regard to corporate
See MoreTaiwan: CFC rules will be effective from 2023
On 16 March 2022, Taiwan’s Ministry of Finance (MOF) issued a press release where it is stated that the controlled foreign company (CFC) rules will be effective from 1 January 2023 for individuals and 2023 taxable year for
See MoreGreece: AADE issues a Circular to provide guidance on CFC rules
On 23 February 2022, the Greek Public Revenue Authority (AADE) published Circular E. 2018 of 23 February 2022, providing guidance on the application of Controlled Foreign Companies (CFC rules). This is introduced as from 1 January 2019 in line with
See MoreUruguay revises list of low or no tax jurisdictions
On 21 February 2022, Uruguay has published DGI Resolution No. 223/022, which updates the list of low or no tax jurisdictions and regimes, with effect from same date. According to the Resolution No. 223/022 the updated list includes 36
See MoreBulgaria approves amendments to the CIT Act
On 20 January 2022, the Bulgarian Parliament passed the draft law amending and supplementing the Corporate Income Tax Act (CITA). The draft law provides for the implementation of the reverse hybrid mismatch rules of the EU Anti-Tax Avoidance
See MoreItaly: IRA Publishes guidance on CFC legislation
On 27 December 2021, the Italian Revenue Agency (IRA) has issued the publication of Circular No. 18/E, that provides guidance regarding the regulations for controlled foreign companies (CFCs) as amended by Article 4 of Legislative Decree No.
See MoreAzerbaijan modifies the Tax Code for TP, CbC Reporting, and CFC rules
On 16 November 2021, Azerbaijan has modified its Tax Code including three main changes regarding Transfer Pricing (TP), country by country (CbC) reports, and controlled foreign company (CFC) rules. The changes will be implemented from 1 January
See MorePoland: President signs new tax bill into Law
On 15 November 2021, the President signed into the Law a bill referred to as "Polski Ład" introducing, amongst others, amendments to the definition of a controlled foreign corporation (zagraniczna jednostka kontrolowana, CFC) to include more
See MorePoland: Lower chamber of parliament passes the tax reform bill
On 1 October 2021, the lower chamber of parliament (the Sejm) of Poland has passed the 3rd reading the bill for the so-called “Polish Deal” tax reform bill. The bill proposes to several tax reform measures including new minimum corporate tax,
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