Russia: MOF clarification on CFC profits
On 5 November 2019, the Russian Ministry of Finance (MOF) issued the letter No. 03-03-06 / 1/85022 concerning the profits of controlled foreign companies (CFC) in cases where a controlling person has an indirect participation in a CFC through legal
See MoreMexico: Congress approves tax reform package for 2020
On 30 October 2019, Mexico’s Congress has approved the tax reform for 2020 which was presented by President Andrés Manuel López Obrador’s on September 8, 2019. The Reform incorporates fundamentals of the Base Erosion and Profit Shifting
See MoreCzech Republic: Parliament debates proposed changes to Income Taxes Act
The Chamber of Deputies debate with some changes to the Income Taxes Act, which may come into force in 2020. The measures must be approved by the Chamber and the Senate and signed by the president before coming into force. The provisions of the
See MoreUkraine submits draft law on amendments to the Tax Code to Parliament
On 30 August 2019, the Ukraine has submitted draft law no. 1210 to the Parliament amending the Tax Code on improving tax administration, removing technical and logical mismatches in the tax legislation. The three main areas of the draft law
See MoreNetherlands: Budget proposal for 2020
On 17 September 2019, the Dutch Government published the 2020 budget proposals, which includes the Tax Plan for 2020. The 2020 Tax Plan package consists of the following six bills: the 2020 Tax Plan Bill;the Other 2020 Tax Measures
See MoreDenmark: Draft bill on international taxation submits for public comments
On 12 September 2019, the Ministry of Taxes published a major bill on international taxation. The bill will be subjected to a public hearing and subsequently presented to the Danish Parliament. Interested parties can submit their comments by 10
See MoreMexico: Tax reform proposal in economic package 2020
On 8 September 2019, Mexican president Andrés Manuel López Obrador’s presented Economic Package for the fiscal year 2020 to Congress. The economic package proposed following tax reform measures: Transparent Entities International
See MoreRussia updates the CFC notification form
On 1 August 2019, the Federal Tax Service (FTS) has approved the amended CFC and the filing procedure in electronic form with an order of 5 July 2019 No. MMV-7-13 / 338. This regulation extends the list of information on foreign organizations
See MoreBulgaria modifies the CFC Rules
The recently published Bulgarian Law amending and supplementing the Tax and Social Security Act includes some modifications and explanations of the rules for Controlled Foreign Companies (CFC), which were introduced with effect from 1 January 2019,
See MoreIreland introduces new Guidance on CFC rules
On 22 July 2019, Ireland has published a new Tax and Duty Manual, Part 35b-01-01 in respect of the Controlled Foreign Company (CFC) rules, that were introduced by Finance Act 2018 and take effect from 1 January 2019. The manual provides an
See MoreIndonesia: MoF changes CFC deemed dividend rules
On 26 June 2019, the Ministry of Finance published a new regulation (No.93/PMK.03/2019(PMK-93) on the controlled foreign corporation (CFC) rules for fiscal year(FY) 2019 which amended the regulation No.107/ PMK.03/2017(PMK-107), concerning the
See MoreGreece transposes the rules of the EU Anti-Tax Avoidance Directive
On 24 April 2019, Greece published Law 4607/2019 in the Official Journal containing measures to implement certain aspects of the EU's Tax Avoidance Directive (ATAD). This includes the replacement of existing rules to bring them in line with ATAD.
See MorePortugal legislates the EU ATAD into domestic law
On 3 May 2019, Portugal published Law n. 32/2019 in the Official Journal which introduced amendments to the Portuguese Tax Law in line with the European Union (EU) Anti-Tax Avoidance Directive (ATAD) provisions. The law amends the following
See MoreCyprus: House of Representatives approves law for ATAD Interest Limitation, CFC, and GAAR Rules
On 5 April 2019, the Cyprus House of Representatives passed a law that addresses certain provisions of the EU anti-tax avoidance directive (ATAD 1) particularly the interest limitation rule, a general anti-avoidance rule (GAAR) and controlled
See MorePeru: SUNAT simplifies the scope of the CFC rules
On 19 March 2019, the Peru tax authority (SUNAT) issued a guidance (No. 011-2019-SUNAT/7T0000) regarding the determination of expenses and loss offsetting under the controlled foreign company (CFC) rules. The guidance clarified that:
See MoreJapan: Parliament enacts tax reform plans for 2019
On 27 March 2019, Japan's parliament approved the legislation for the government's tax reform proposals for 2019. Some of the main measures are following: Tax incentive: As from 1 April 2019, the tax credit rates will be revised to enhance
See MoreCzech Republic published law including CFC rules
On 27 March 2019, the Czech Republic released the Law of 12 March 2019, which includes CFC rules among other changes. A foreign company or permanent establishment will be considered controlled foreign company (CFC) for tax purpose if the Czech
See MoreBolivia updates list of tax haven jurisdiction
On 15 February 2019, Bolivia's National Tax Service issued Resolution No. 101900000002 to update the list of jurisdictions considered to have low or no taxation, which also contains jurisdictions recognized as non-cooperative, applies from the date
See More