Ireland: President signs the Finance Bill 2020 into Law
On 19 December 2020, the President signed the Finance Bill 2020 into Law, which underpins the Government’s support for the economy in the face of Covid-19 pandemic and the ongoing threat of a no-deal Brexit. The Finance Act 2020 provisions
See MoreGreece: AADE publishes preferential tax regime status for the 2019
On 7 December 2020, the Greek Public Revenue Authority (AADE) published Circular No. A.1267 of 7 December 2020, which determines the states that have a preferential tax regime based on the provisions of par. 6 and 7 of article 65 of law 4172/2013
See MoreUkraine: Parliament accepts changes to recently implemented BEPS legislation
On 17 December 2020, the Ukrainian Parliament has accepted a tax reform bill, which contains important changes to recently implemented BEPS legislation. The following important changes were introduced related to recently implemented BEPS and other
See MoreHungary: Parliament approves tax omnibus bill including CFC Rules
On 13 October 2020, the Hungarian parliament approved a Bill No. T/13258, to amend various taxation laws. The bill contains the following measures: Disallow company income tax exemptions to controlled foreign companies from EU blacklisted
See MoreSweden proposes to deny deductions for interest expenses regarding debts to EU blacklist countries
On 3 September 2020, the Swedish Government has announced to deny deductions for interest expenses regarding debts to EU blacklist countries. The EU's work against tax planning and harmful tax competition has been going on for a long
See MoreMalta: Commissioner for Revenue issues ATAD implementation Guidelines
On 31 August 2020, the Maltese Commissioner for Revenue has issued Guidelines in relation to the Anti-Tax Avoidance Directives Implementation Regulations (ATAD) on its website. The guidelines on the ATAD Implementation Regulations were issued in
See MoreUkraine: SFS releases guidance letter on new CFC rules
On 17 August 2020, the Ukraine State Fiscal Service (SFS) has issued a guidance letter 3380/IPK/99-00-05-05-02-09, which clarifies the taxation of profits of controlled foreign companies (CFCs). In Ukraine, the CFC rule will be applicable from 1
See MoreUS: IRS publishes revised practice unit on dividends or interest from a related CFC
On 29 July 2020, the U.S. IRS published a revised international practice unit on the Receipt of Dividends or Interest from a Related CFC. The practice unit was revised to include the extension of the IRC 954(c)(6) look through rule for CFCs with
See MoreRussia aims to introduce fixed tax of RUB 5 million on CFC income
The government of Russia is planning several tax measures to be introduced in 2021 including an increased 15% tax rate applies on high-earning individuals and reduced 3% tax rate on Information Technology enterprises. In addition to these
See MoreUkraine: President signs law to implement BEPS and other provisions
On 21 May 2020, the President of Ukraine signed Law No. 466-IX (Draft Law No.1210) “On Amendments to the Tax Code of Ukraine on Improvement of Tax Administration, Elimination of Technical and Logical Inconsistencies in Tax Legislation", which was
See MoreUS: Tax court ruled in favor of the IRS for Whirlpool vs Commissioner case
On 5 May 2020, the US tax court made a decision in favor of the IRS a case involving the Whirlpool Financial Corp. and related foreign affiliate corporations. The Court upheld the Internal Revenue Service's (IRS) application of the Subpart F
See MoreDenmark: President announces to postpone a Bill for amending CFC rules
On 15 April 2020, the Prime Minister informed the president of the parliament that some of proposed legislation need to be postponed during COVID-19 pandemic. One of the proposed legislation is Bill L48, which provides the transpose in existing CFC
See MoreLuxembourg: Tax Authority issues new guidance on CFC rules
On 4 March 2020, the Luxembourg Tax Authority has issued Circular n°164ter/1 on the controlled foreign corporation (CFC) rules. Luxembourg enacted CFC rules as part of the implementation of the EU Anti-Tax Avoidance Directive (ATAD) on 21 December
See MoreUkraine: Parliament adopts draft law on amendments to the Tax Code
On 16 January 2020, the Ukrainian Parliament adopted Law No 1210 on amendments to the Tax Code of Ukraine with regard to improvement of tax administration, elimination of technical and logical discrepancies in tax legislation. The important
See MoreSouth Africa: President signs five revenue related Bills into Law
On 21 January 2020, the National Assembly released a Media Statement, which provides that on 13 January 2020, President, Cyril Ramaphosa, signed into law five different revenue related bills. These bills, which have now been promulgated include the
See MoreBulgaria: Parliament accepts tax loss carry forward for CFC
The Parliament recently approved tax loss carry forward rules for controlled foreign companies (CFC). It was stated that the losses may be carried forward for up to five years and should be applied to tax losses incurred after December 31,
See MoreArgentina: Executive Power publishes Executive Branch Decree 862/2019
On 9th December 2019, the Executive Power published Executive Branch Decree 862/2019 in the Official Gazette, which approves a new revised text of the regulatory decree of the Income Tax Act and incorporated provisions that were contained in
See MoreMexico implements economic package 2020
On 9 December 2019, Mexico has published a decree to implement economic package 2020 which was approved by Mexican Congress on 30 October 2019. This Decree will enter into force on January 1, 2020. The economic package consists of the following
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