Nigeria gazettes tax reform acts, updates corporate and minimum effective tax rates
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
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Taiwan: 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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Ecuador updates tax haven and preferential regime guidelines
Ecuador's Internal Revenue Service (SRI) has published Circular NAC-DGECCGC25-00000002 on 21 January 2025, outlining new guidelines for identifying tax havens, preferential tax regimes, and low-tax jurisdictions. A regime or or jurisdictions
See MoreTaiwan updates low-tax jurisdictions list
Taiwan's Ministry of Finance (MOF) released an updated list of low-tax jurisdictions on 27 December 2024. Controlled Foreign Company (CFC) rules, which have been in effect in Taiwan since the 2023 tax year, were introduced to prevent companies or
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Ukraine suspends CFC reporting fines during martial law
Ukraine’s president, Volodymyr Zelensky has signed Law No. 9319 on 25 December 2024 which postpones a new military tax hike for small businesses and individual taxpayers until 1 January 2025. Under this law, Ukrainian residents will not be fined
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Russia: MoF clarifies loss carry-forward rules for CFCs redomiciled as international companies
The Russian Ministry of Finance (MoF) clarified in Guidance Letter No. 03-12-11/2/107192, published on 9 December 2024 that, under certain conditions, losses can be carried forward by a controlled foreign company (CFC) registered in Russia and
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Belgium publishes guidance on new CFC rules
Belgium’s tax authorities have issued two circular letters - Circular 2024/C/82 and Circular 2024/C/83 - on 13 December 2024 - providing clarity on specific aspects of the controlled foreign company (CFC) rules introduced in 2023. The amended
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Austria updates CFC rules to prevent double taxation under Pillar Two
Austria's parliament has amended its CFC rules to avoid double taxation issues under the Pillar Two global minimum tax framework. Amendments to Section 10a of the Austrian Corporate Income Tax Act have been approved and now require Qualified
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