Taiwan publishes CFC rules for foreign residents
Taiwan's Ministry of Finance has released a notice regarding the application of Controlled Foreign Company (CFC) rules to foreign residents meeting the country's residency criteria. The notice states that foreign nationals, who lived in Taiwan
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Czech Republic updates non-cooperative jurisdictions list for CFC rules
The Czech Republic Ministry of Finance issued the Financial Bulletin No. 3/2024, on 28 February, 2024, which contains an updated notice regarding the list of non-cooperative jurisdictions concerning the Czech Republic's Controlled Foreign Company
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Russia: MoF clarifies tax exemption for CFC amid treaty suspensions
The Guidance Letter No. 03-12-11/2/11449, published by the Russian Ministry of Finance (MoF) on 12 February, 2024, addresses the tax exemption applicable to profits of Controlled Foreign Companies (CFCs) situated in jurisdictions with which Russia
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Sweden considers new permanent residency rules for taxation
Sweden's Ministry of Finance announced, on 3 May, 2024, a significant update regarding permanent residency criteria for tax purposes. Following the release of a memorandum by the Tax Agency in November, 2023, proposing a redefinition of permanent
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Italy introduces CFC substitute tax measures
Italyโs Revenue Agency has published provisions for Controlled Foreign Company (CFC) substitute tax option, released as part of Legislative Decree No. 209 of 27 December 2023. Legislative Decree No. 209 outlines measures for adopting the Pillar
See MoreTaiwan: Ministry of Finance relaxes taxation for CFC
The Ministry of Finance in Taiwan has released a notification regarding eased taxation regulations concerning profits from Controlled Foreign Corporations (CFCs) invested in enterprises situated in non-low-tax jurisdictions that are acknowledged
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Ukraine issues controlled foreign companies (CFC) notification requirements
On 28 March 2024, the State Tax Service of Ukraine released a notice directed to companies and individuals residing in Ukraine, detailing their duty to report on controlled foreign companies. This notification outlines the requirement for
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France updates non-cooperative states and territories list
The French General Tax Code's list of non-cooperative States and territories (NCSTs) was updated via Decree on 16 February 2024 and published in the Official Journal on 17 February 2024. The list includes the following 16 states and territories:
See MoreSweden: MoF proposes updates to pillar 2 global minimum tax rules
On 19 March 2024, the Swedish Ministry of Finance (MoF) released proposed amendments to the Act on Additional Tax, aimed at incorporating the Pillar 2 global minimum tax as outlined in Council Directive (EU) 2022/2523. As per the proposal, a
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Ecuador: SRI updates list of tax haven jurisdiction
On 20 February 2024, the Ecuador Internal Revenue Service (SRI) amended Resolution No. NAC-DGERCGC15-00000052 through Resolution No. NAC-DGERCGC24-00000007. As per the amendment, the tax authority included the following countries and territories as
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Japan submits tax reform bill 2024 to parliament
On 2 February 2024, the Japanese Cabinet submitted the tax reform bill 2024 to parliament. The bill covers various tax measures. Key measures of the bill include: Driving Domestic Growth: The introduction of new tax credit incentives is
See MoreUkraine mandates reporting of controlled foreign companies (CFCs)
On 6 February 2024, the State Tax Service of Ukraine issued a release outlining the mandatory reporting of controlled foreign companies. The State Tax Service of Ukraine informs that the campaign for submission by controlling persons of Reports on
See MoreRussia: FTS updates list of jurisdictions that do not exchange proper information for CFC purpose
On 10 January 2024, the Russian Federal Tax Service (FTS) published updated list of jurisdictions that do not exchange tax information with Russia (Decree No. ะD-7-17/914). The list pertains to the tax exemption for profits of controlled foreign
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Belgium approves 2024 budget Introducing new CFC rulesย
Belgium has approved the 2024 budgetary measures, including new CFC rules, increased progressive tax on credit institutions, and strengthening Cayman tax rules. New CFC rules One key aspect of Belgiamโs CFC rules is the implementation of the
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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 taxย
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
See MoreBelgium 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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