Sweden 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
See MoreBulgaria: Government publishes Law on Amendments to the Corporate Income Tax Act
On 6 December 2019, Law on Amendments to the Corporate Income Tax Act was published in the Official Gazette and it was adopted by the National Assembly on 21st November 2019. Similar amendments in Controlled Foreign Company (CFC) and transfer
See MoreRussia updates CFC notification form
On 18 November 2019, the Russian Federal Tax Service published updated controlled foreign company (CFC) notification form with e-filing instruction. This form applies from 1 January
See MoreDenmark publishes the Bill no. L 48 on international taxation
On 6 November 2019, the Danish Minister of Taxation published Bill no. L 48 on international taxation. The bill updated the existing PE (permanent establishment) rules, CFC rules and strengthen the Transfer pricing (TP) rules. PE rules: The
See MoreBulgaria proposes changes to the Corporation Tax Act
On 12 November 2019, a proposal to changes the Corporation Tax Act was submitted to Parliament. The law proposed the following measures: propose to amendments the thin capitalization rules in order to increase the level of expenditure that is
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