Bulgaria 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,
See MorePoland: Government plans to extend the scope of CFC rules
On 8 September 2021, the Polish government submitted a bill to the Parliament including the proposal extending the application of the CFC rules. The proposal includes the following changes: Extension of the definition of a foreign legal entity
See MoreKorea: MOEF proposes Tax Revision Bill 2021
On 26 July 2021, South Korea’s Ministry of Economy and Finance (MOEF) has issued an overview of the proposed Tax Revision Bill 2021 to support new industries and employment, as well as inclusive growth. The Tax Revision Bill 2021 includes the
See MoreUkraine: STS releases guidance letter on tax treaty requirements under CFC rules
On 12 July 2021, the State Tax Service (STS) has issued a guidance letter 2712/IPK/ 99-00-21-02-02-06 which clarifies tax treaty requirements under CFC rules. The guidance letter clarifies that from 1 January 2022 CFC profits may be exempt from
See MoreDenmark: Parliament approves ATAD amendments to CFC rules
On 3 June 2021, the Danish Parliament approved a Bill L 89 to amend the controlled foreign company (CFC) rules with the purpose of bringing them in line with the EU Anti-Tax Avoidance Directive (ATAD). The major mechanism in the Danish CFC rules
See MoreDenmark: Ministry of Taxation launches a public consultation regarding CFC rules
On 23 April 2021, the Ministry of Taxation announced a public consultation for amending a draft Bill L 89. This Bill proposes for an Act amending the Corporation Tax Act and the Capital Gains Tax Act (Implementation of the minimum requirements of
See MoreUS: IRS publishes revised CFC practice unit guidelines
On 22 March 2021, the U.S. Internal Revenue Service has published a revised international practice unit on Receipt of Dividends or Interest from a Related CFC. This Unit was revised to include the extension of the IRC 954(c)(6) look through rule
See MoreIreland: Revenue issues eBrief regarding guidance on CFC rules
On 12 February 2021, the Irish Revenue issued eBrief No. 027/21, which provides updated guidance regarding controlled foreign company (CFC) rules. On the similar day, the Revenue also published a Tax and Duty Manual, providing guidance of how to
See MoreSouth Africa: Government Officially publishes 2020 Tax Amendment Acts
On 20 January 2021, the Treasury Department Officially published the 2020 Tax Amendment Acts. The following Amendment Acts were promulgated: Rates and Monetary Amounts and Amendment of Revenue Laws Act 22 of 2020.Taxation Laws Amendment Act 23
See MoreIreland: President signs the Finance Bill 2020 into Law
On 19 December 2020, the President signed the Finance Bill 2020 into Law, which underpins the Government’s support for the economy in the face of Covid-19 pandemic and the ongoing threat of a no-deal Brexit. The Finance Act 2020 provisions
See MoreGreece: AADE publishes preferential tax regime status for the 2019
On 7 December 2020, the Greek Public Revenue Authority (AADE) published Circular No. A.1267 of 7 December 2020, which determines the states that have a preferential tax regime based on the provisions of par. 6 and 7 of article 65 of law 4172/2013
See MoreUkraine: Parliament accepts changes to recently implemented BEPS legislation
On 17 December 2020, the Ukrainian Parliament has accepted a tax reform bill, which contains important changes to recently implemented BEPS legislation. The following important changes were introduced related to recently implemented BEPS and other
See MoreHungary: Parliament approves tax omnibus bill including CFC Rules
On 13 October 2020, the Hungarian parliament approved a Bill No. T/13258, to amend various taxation laws. The bill contains the following measures: Disallow company income tax exemptions to controlled foreign companies from EU blacklisted
See MoreSweden proposes to deny deductions for interest expenses regarding debts to EU blacklist countries
On 3 September 2020, the Swedish Government has announced to deny deductions for interest expenses regarding debts to EU blacklist countries. The EU's work against tax planning and harmful tax competition has been going on for a long
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