Lithuania updates its blacklist in various tax aspects
On 30 November 2023, Lithuania issued an order revising its list of selected territories (blacklist), incorporating Russia as a new addition. The blacklist plays a crucial role in various tax aspects, including Lithuania's CFC rules. List of
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Germany updates tax haven defense ordinance: Adds and removes jurisdictions in response to EU decision
On 20 December 2023, Germany issued the Ordinance, amending the Tax Haven Defense Ordinance, as published in the Official Gazette. The Tax Haven Defense Ordinance plays a critical role in identifying jurisdictions considered non-cooperative under
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Italy: CFC rules related to GloBE pillar 2 amended to include 15% tax rate option and substitute tax
On 19 December 2023, Italy's Council of Ministers passed a legislative decree to enforce the tax reforms related to international taxation. This includes implementing the Pillar 2 global minimum tax under Council Directive (EU) 2022/2523 of 14
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Belgium proposes new draft law for CFC rules
The Belgian government has submitted a new draft bill to parliament for implementing stricter rules concerning the taxation of the undistributed income of a controlled foreign company (CFC), shifting from model B (targeting tax avoidance
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Germany: MOF issues draft guidance on anti-tax avoidance measures
On 30 November 2023, the German Ministry of Finance (MoF) issued draft guidance on anti-tax avoidance measures targeting non-cooperative jurisdictions. This follows the 2021 Tax Haven Defense Act, responding to EU guidelines against harmful tax
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Russia: FTS updates non cooperative Jurisdictions list for CFC purpose
On 14 November 2023, the Federal Tax Service (FTS) is in the process of updating its list of jurisdictions that do not meet Russia's standards for tax information exchange. The list of countries that do not cooperate with Russia on tax matters
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Russia: MOF publishes tax policy plans for 2024
On 2 November 2023, the Ministry of Finance in Russia released a statement regarding the tax policy proposals announced by State Secretary and Deputy Minister of Finance, Alexey Sazanov, during a recent event hosted by the B1 company. The statement
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Belgium: Federal Government agrees on budget measures for FY 2024
On 9 October 2023, the Belgian government agreed on Budget measures for the fiscal year 2024. Here is a broad summary of the key tax measures in the budget agreement, as announced by the finance minister. The proposed key measures are
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Russia amends regulations on taxation of controlled foreign companies
On 31 August 2023, the government of Russia announced new tax rules that will exempt profits of foreign collective investment structures from taxation. The exemption will apply if the following conditions are met: The profit of the structure is
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Germany: BMF publishes draft guidance on CFC legislation
On 20 July 2023, the Federal Ministry of Finance (BMF) issued draft guidance concerning the implementation of the Foreign Transactions Tax Act (FTTA), specifically addressing the taxation aspects related to controlled foreign corporations (CFCs).
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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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