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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Sweden: 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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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
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Ukraine 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
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Belgium approves 2024 budget Introducing new CFC rules
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 Belgiam’s CFC rules is the implementation of the
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Germany: MOF issues draft guidance on anti-tax avoidance measures
On 30 November 2023, the German Ministry of Finance (MoF) issued draft guidance on anti-tax avoidance measures targeting non-cooperative jurisdictions. This follows the 2021 Tax Haven Defense Act, responding to EU guidelines against harmful tax
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Russia amends regulations on taxation of controlled foreign companies
On 31 August 2023, the government of Russia announced new tax rules that will exempt profits of foreign collective investment structures from taxation. The exemption will apply if the following conditions are met: The profit of the structure is
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Germany: BMF publishes draft guidance on CFC legislation
On 20 July 2023, the Federal Ministry of Finance (BMF) issued draft guidance concerning the implementation of the Foreign Transactions Tax Act (FTTA), specifically addressing the taxation aspects related to controlled foreign corporations (CFCs).
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US: IRS publishes practice units on interest expense limitations
On 16 May 2023, the IRS Large Business and International (LB&I) division issued two practice units in relation to interest expense limitations for related party loans. Interest Expense Limitation on Related Foreign Party Loans Under IRC
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Brazil publishes law extending certain CFC benefits
On 13 April 2023, Law No. 14.547 transposing Provisional Measure 1148/2022 into law was published in the Brazilian Official Gazette, which extends certain benefits in regard to the controlled foreign company (CFC) rules under Law 12,973/14. Under
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Singapore: IRAS releases guidance on tax treatment of gains or losses from the sale of foreign assets
On 8 December 2023, the Inland Revenue Authority of Singapore (IRAS) released an updated e-tax guide on the tax treatment of gains or losses from the sale of foreign assets under the recently introduced Section 10(L) of the Income Tax Act (ITA).
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Taiwan provides the list of low-tax jurisdictions under CFC rules
On 13 December 2022, the Ministry of Finance of Taiwan issued a press release providing the list of low-tax jurisdictions under controlled foreign company (CFC) rules. The CFC rules will be effective from 1 January 2023 for profit-making enterprises
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Russia updates non cooperative Jurisdictions list for CFC purpose
On 5 December 2022, the Federal Tax Service of Russia published Order No. ED-7-17/987 in the Official Gazette which provides an update list of jurisdictions that do not have acceptable tax information exchange with Russia. The list applies in
See MoreUkraine: STS explains international taxation during martial law
On 3 August 2022, the State Tax Service (STS) of Ukraine explained the rights and obligations of taxpayers and supervisory authorities in matters of international taxation during martial law, taking into account the Ukraine- Russia war. Statute
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Poland: MoF proposes important amendments to corporate income tax law
On 28 June 2022, the Polish government announced a draft law to proposing significant changes to the Polish Corporate Income Tax Act. The proposed changes impact the following areas; The effective date of the new “minimum tax” will be
See MoreLuxembourg: Tax Authority updates guidance on CFC rules
On 17 June 2022, the Luxembourg Tax Authority published Circular n°164ter/1 (the guidance) on the controlled foreign corporation (CFC) rules. The guidance includes the following topics: Foreign controlled companies with regard to corporate
See MoreTaiwan: CFC rules will be effective from 2023
On 16 March 2022, Taiwan’s Ministry of Finance (MOF) issued a press release where it is stated that the controlled foreign company (CFC) rules will be effective from 1 January 2023 for individuals and 2023 taxable year for
See MoreGreece: AADE issues a Circular to provide guidance on CFC rules
On 23 February 2022, the Greek Public Revenue Authority (AADE) published Circular E. 2018 of 23 February 2022, providing guidance on the application of Controlled Foreign Companies (CFC rules). This is introduced as from 1 January 2019 in line with
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