Taiwan: Tax Bureau clarifies CFC investment income deductions
Taiwan’s National Taxation Bureau, under the Ministry of Finance, has clarified rules on the calculation of Controlled Foreign Company (CFC) investment income for profit-seeking enterprises, emphasising that accumulated losses recorded in a
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Austria: MOF consults 2025 tax reform, proposes updates to Pillar 2 rules
Draft bill introduces income tax inflation adjustments and updates to global minimum tax rules, with consultation open until 3 November 2025. The Austrian Ministry of Finance (MOF) has released the draft Tax Amendment Act 2025
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Japan updates guidance on global minimum tax
NTA updated its guidance on global minimum tax rules, clarifying calculations and key definitions. Japan's National Tax Agency (NTA) released a revised version of its interpretative guidance on global minimum tax rules on 26 September
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Kazakhstan: MoF approves new CFC reporting, taxation forms for 2026
Ministry of Finance introduced new forms for reporting and taxing Controlled Foreign Companies, effective 1 January 2026. Kazakhstan’s Ministry of Finance issued Order No. 536 on 25 September 2025, approving new forms for the reporting and
See MoreKazakhstan: MOF updates CFC preferential tax jurisdictions list
 Kazakhstan approved a 56-country CFC preferential tax list, effective from 1 January 2026. Kazakhstan’s Ministry of Finance (MOF) approved Order No. 492 of 12 September 2025, updating the list of countries and territories with preferential
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Ukraine: STS clarifies CFC reporting penalties
Ukraine requires annual CFC reports, with penalties waived during martial law if filed within six months after it ends. Ukraine’s State Tax Service (STS) has clarified that, under the country’s controlled foreign company (CFC) rules, a
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Nigeria gazettes tax reform acts, updates corporate and minimum effective tax ratesÂ
The Nigeria Tax Act 2025 and the Nigeria Tax Administration Act 2025, which will take effect on 1 January 2026, as well as the Nigeria Revenue Service (Establishment) Act 2025 and the Joint Revenue Board (Establishment) Act, which came into force on
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Chile clarifies indirect foreign tax credit treatment for CFCs
Ruling No. 1500-2025 confirms that the indirect foreign tax credit applies only if a treaty or information exchange agreement exists and the CFC owns at least 10% of the subsidiary. Chile’s tax administration (SII) issued Ruling No. 1500-2025
See MoreTaiwan: MoF clarifies direct and indirect holdings count in CFC rules
The finance ministry confirms both direct and indirect related-party ownership count when determining CFC status in low-tax jurisdictions. Taiwan’s Ministry of Finance has released a statement on 31 July 2025 clarifying that in assessing
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Italy implements emergency tax revisions on CFC, hybrid mismatch penalty rules
Urgent tax measures include revising the domestic CFC rules, tax loss carry-forward provisions, and the penalty protection regime for hybrid mismatch assessments. Italy’s parliament converted Law Decree No. 84 of 17 June 2025 into law with
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Taiwan: MOF tightens CFC loss submission rules
The finance ministry mandated that CFC losses are deductible only if audited statements or equivalent proof are filed by the tax deadline (plus a one-time six-month extension); otherwise, they're disallowed. Taiwan’s Ministry of Finance has
See MoreTaiwan: MoF warns enterprises on timely CFC loss reporting
The finance ministry stated that CFC losses need supporting documents by the tax deadline, or they won’t be allowed. Taiwan’s Ministry of Finance (MOF) stated that CFC losses will be disallowed unless supporting documents are submitted by the
See MoreTaiwan issues CFC exemption guidelines for 2025 compliance
New guidance confirms Taiwan’s CFC exemption applies to entities with limited earnings or substantial operations. Taiwan’s Ministry of Finance has released a notice to specify the exemption limit for current-year income under the Controlled
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Italy amends CFC rules, tax loss carry-forward provisions
The adopted tax measures include updates to controlled foreign company (CFC) rules and tax loss carry-forward provisions. Italy has published Decree No. 84 of 17 June 2025 in Official Gazette No. 138 on 17 June 2025, introducing changes to the
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Kazakhstan revises tax treaty list for CFC rules
Kazakhstan has updated its list of jurisdictions eligible for CFC rule exemptions, removing several countries and Swiss cantons, effective 22 May 2025. Kazakhstan issued Order No. 247 on 22 May 2025, amending Order No. 680 of 19 June 2023. The
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Ireland: Revenue updates CFC rules in eBrief 023/25
The Irish Revenue released eBrief 023/25 on 24 January 2025, which includes updates to the tax and duty manual on Controlled Foreign Company (CFC) rules, in light of the changes introduced by the Finance Act 2024. Tax and Duty Manual - Part
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Chile clarifies CFC rules, updates preferential tax jurisdictions
Chile’s tax administration published Circular Letter 11/2025 on 30 January 2025, which introduced Law 21.713, regarding controlled foreign company (CFC) regulations, preferential tax regimes, and the indirect sale of assets in Chile. The Law
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Indonesia updates CRS participating and reportable jurisdictions for 2025
Indonesia's Directorate General of Taxes has published Announcement No. 1/PJ/2025 on 24 January 2025, listing the participating and reportable jurisdictions for the 2025 automatic exchange of financial account information under the Common Reporting
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