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
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Taiwan 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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Czech Republic updates list of non-cooperative CFC jurisdictions
The Czech Republic Ministry of Finance has released Financial Bulletin No. 9/2024, containing a notice regarding the lists of non-cooperative jurisdictions for various periods about the Czech Republic's controlled foreign company (CFC)
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US: IRS clarifies CFC not eligible for dividends received deduction under section 245A
The US Internal Revenue Service (IRS) issued an Office of Chief Counsel memorandum clarifying that a controlled foreign corporation (CFC) is not eligible for a dividends received deduction under section 245A. This memorandum provides
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Chile updates tax compliance law, introduces changes to GAAR, transfer pricing, and CFC
Chile's Internal Revenue Service (SII) has announced that the Law on Compliance with Tax Obligations (Law No. 21.713) has been published in the Official Gazette on 24 October 2024. General and Special Anti-Avoidance Rules changes The General
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Latvia updates list of tax havens, removes Antigua and Barbuda
Latvia announced an updated list of low-tax and tax-free jurisdictions in the Official Gazette on 23 October 2024. This list, derived from the latest EU list of non-cooperative jurisdictions, notes the removal of Antigua and Barbuda, effective 1
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Chile: Parliament passes tax compliance bill
Chile’s Chamber of Deputies have passed the Tax Compliance Bill (Proyecto de Ley de Cumplimiento de las Obligaciones Tributarias). Earlier, Chile’s Senate approved the Tax Compliance Bill on 24 September 2024 which included key changes to
See MoreTaiwan introduces CFC De minimis rule for profit seeking enterprises
Taiwan's Ministry of Finance has announced a de minimis test enabling profit-seeking enterprises to avoid recognizing investment income under the CFC Rules on September 2024. The National Taxation Bureau of the Southern Area, Ministry of Finance
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Ireland named amongst top 10 tax havens globally
According to the Tax Justice Network's latest ranking report published on 1 October 2024, Ireland has surpassed the Bahamas to become the ninth-largest tax haven in the world. A spokesperson for Ireland's Department of Finance has denied that the
See MoreChile passes tax compliance bill with income, VAT, transfer pricing measures
Chile’s Senate has approved the Tax Compliance Bill on 24 September 2024, which will be presented to the Lower House for final approval. The newly approved tax measures include modifications to the general anti-avoidance rule (GAAR), statute of
See MoreRussia updates list of jurisdictions without adequate information exchange for CFC purposes
The Russian Federal Tax Service is in the process of completing a draft order that will update the list of jurisdictions lacking sufficient tax information exchange with Russia. This new list will supersede the Order No. ED-7-17/914 @ of 1 December
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Argentina removes five countries from non-cooperative jurisdictions list
Argentina has issued Decree 603/2024 of 10 July 2024, updating the list of non-cooperative jurisdictions for tax purposes as defined under Decree 862/2019. In this revised non-cooperative jurisdictions list, it removed Burkina Faso, Benin, Papua New
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Russia introduces tax reform draft laws
Russia's Ministry of Finance presented a set of draft laws to the Russian Government intended to enhance the tax system on 29 May, 2024. The package contains several major amendments to the Tax Code, Budget Code and Budget Law for 2024 and the
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Germany issues guidelines to combat tax havens
The German Ministry of Finance has released guidance on implementing the Tax Haven Defense Act, formerly the Act to Prevent Tax Avoidance and Unfair Tax Competition. This guidance introduces stringent measures to decrease business dealings with
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