Taiwan clarifies CFC rules on low-tax jurisdiction gains, losses
Taiwan’s Northern National Taxation Bureau of the Ministry of Finance has reminded profit-seeking enterprises that when calculating Controlled Foreign Corporation (CFC) annual earnings, investment gains or losses originating from “low-tax
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Russia updates VAT, corporate tax rules
Russia has enacted a series of tax reforms for 2026 under Federal Law No. 425-FZ of 28 November 2025, introducing changes across VAT, corporate taxation, and digital asset regulation. The reforms took effect on 1 January 2026. The standard VAT
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Germany: Bundesrat approves Pillar 2 tax amendments, DAC 9 information exchange
Germany ’s Federal Council (Bundesrat) approved a bill (Gesetz zur Anpassung des Mindeststeuergesetzes und zur Umsetzung weiterer Maßnahmen) on 19 December 2025 amending the country’s Pillar 2 minimum taxation framework. The bill updates the
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Taiwan clarifies CFC financial statement deadline applications
The Northern Taiwan National Taxation Bureau of the Ministry of Finance stated that, in line with international anti-tax avoidance trends and to maintain tax fairness, Taiwan’s Controlled Foreign Corporation (CFC) regime has been implemented
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Taiwan: Tax Bureau clarifies CFC investment income deductions
Taiwan’s National Taxation Bureau, under the Ministry of Finance, has clarified rules on the calculation of Controlled Foreign Company (CFC) investment income for profit-seeking enterprises, emphasising that accumulated losses recorded in a
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Austria: MOF consults 2025 tax reform, proposes updates to Pillar 2 rules
Draft bill introduces income tax inflation adjustments and updates to global minimum tax rules, with consultation open until 3 November 2025. The Austrian Ministry of Finance (MOF) has released the draft Tax Amendment Act 2025
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Japan updates guidance on global minimum tax
NTA updated its guidance on global minimum tax rules, clarifying calculations and key definitions. Japan's National Tax Agency (NTA) released a revised version of its interpretative guidance on global minimum tax rules on 26 September
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Kazakhstan: MoF approves new CFC reporting, taxation forms for 2026
Ministry of Finance introduced new forms for reporting and taxing Controlled Foreign Companies, effective 1 January 2026. Kazakhstan’s Ministry of Finance issued Order No. 536 on 25 September 2025, approving new forms for the reporting and
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Ukraine: STS clarifies CFC reporting penalties
Ukraine requires annual CFC reports, with penalties waived during martial law if filed within six months after it ends. Ukraine’s State Tax Service (STS) has clarified that, under the country’s controlled foreign company (CFC) rules, a
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Chile clarifies indirect foreign tax credit treatment for CFCs
Ruling No. 1500-2025 confirms that the indirect foreign tax credit applies only if a treaty or information exchange agreement exists and the CFC owns at least 10% of the subsidiary. Chile’s tax administration (SII) issued Ruling No. 1500-2025
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Taiwan: MOF tightens CFC loss submission rules
The finance ministry mandated that CFC losses are deductible only if audited statements or equivalent proof are filed by the tax deadline (plus a one-time six-month extension); otherwise, they're disallowed. Taiwan’s Ministry of Finance has
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Taiwan: MoF warns enterprises on timely CFC loss reporting
The finance ministry stated that CFC losses need supporting documents by the tax deadline, or they won’t be allowed. Taiwan’s Ministry of Finance (MOF) stated that CFC losses will be disallowed unless supporting documents are submitted by the
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Taiwan issues CFC exemption guidelines for 2025 compliance
New guidance confirms Taiwan’s CFC exemption applies to entities with limited earnings or substantial operations. Taiwan’s Ministry of Finance has released a notice to specify the exemption limit for current-year income under the Controlled
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Italy amends CFC rules, tax loss carry-forward provisions
The adopted tax measures include updates to controlled foreign company (CFC) rules and tax loss carry-forward provisions. Italy has published Decree No. 84 of 17 June 2025 in Official Gazette No. 138 on 17 June 2025, introducing changes to the
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Ireland: Revenue updates CFC rules in eBrief 023/25
The Irish Revenue released eBrief 023/25 on 24 January 2025, which includes updates to the tax and duty manual on Controlled Foreign Company (CFC) rules, in light of the changes introduced by the Finance Act 2024. Tax and Duty Manual - Part
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Chile clarifies CFC rules, updates preferential tax jurisdictions
Chile’s tax administration published Circular Letter 11/2025 on 30 January 2025, which introduced Law 21.713, regarding controlled foreign company (CFC) regulations, preferential tax regimes, and the indirect sale of assets in Chile. The Law
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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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