Taiwan clarifies CFC exemption criteria under anti-avoidance rules
Taiwan’s National Taxation Bureau of the Northern Area (NTBNA) has reiterated, on 28 July 2026, the key exemption criteria under the country’s Controlled Foreign Company (CFC) regime, urging businesses to ensure compliance with the rules when
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Netherlands: CFC levy cannot offset low-tax free investments under participation exemption
The Dutch Tax Administration issued a clarification on 21 July 2026, explaining that the controlled foreign company (CFC) levy does not take low-tax-free investments into account. The recent clarification by the Dutch Tax Administration provides
See MoreTaiwan clarifies CFC loss deduction filing, documentation requirements
Taiwan’s National Taxation Bureau of Taipei, Ministry of Finance, stated that the Controlled Foreign Corporation (hereinafter referred to as CFC) system has been in effect since 2023. Profit-seeking enterprises reporting CFC's losses must provide
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Taiwan: Businesses reminded to apply for CFC financial statement filing extensions
The Kaohsiung National Taxation Bureau of the Ministry of Finance announced on 25 May 2026 that, for any reason, those who are unable to submit their CFC financial statements within the prescribed period may apply to their local tax authority for an
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Taiwan: Tax bureau reminds firms of CFC financial statement filing deadline
Taiwan’s Northern Taiwan National Taxation Bureau of the Ministry of Finance announced that the filing period for the 2025 profit-seeking enterprise income tax return is from May 1 to May 31, 2026 (extended to June 1 if the deadline falls on a
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Taiwan clarifies CFC document extension rules for corporate tax filings
Taiwan’s Central District National Taxation Bureau of the Ministry of Finance clarified that profit-seeking enterprises required to report income from Controlled Foreign Corporations (CFCs) must disclose relevant information and attach supporting
See MoreTaiwan tightens 2023 CFC audits, flags misreported income breaching de minimis threshold
Taiwan’s National Taxation Bureau of the Northern Area, MOF, stated, on 30 April 2026, that it has strengthened audits of Controlled Foreign Corporation (CFC) cases for the year 2023 on profit-seeking enterprise income tax filings within its
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Montenegro proposes draft corporate tax rules in accordance to EU ATAD
The Government of Montenegro has released a draft law on Amendments to the Law on Corporate Income Tax, proposing measures to address profit shifting in accordance with the EU Anti-Tax Avoidance Directive (ATAD) (Directive 2016/1164 as amended by
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Italy: Revenue Agency updates tax codes for transition 5.0 credit, CFC regime
The Italian Revenue Agency has introduced new tax codes to facilitate payments under two distinct fiscal frameworks: the Transition 5.0 plan and the reformed controlled foreign companies (CFC) regime. These updates aim to streamline tax compliance
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Russia urges individuals to submit CFC notifications before April deadline
The Russian Federal Tax Service has issued a reminder that individuals are required to submit the annual notification on controlled foreign companies (CFCs) for the 2025 tax year by 30 April 2026. This obligation applies regardless of the financial
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Japan enacts 2026 tax reform, implements side-by-side safe harbour
Japan’s National Diet approved the 2026 tax reform legislation on 31 March 2026, which has been published in the Official Gazette. The measures reflect proposals released in December 2025 and January 2026, covering income, corporate,
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Sweden implements Side-by-Side, UPE safe harbours under global minimum tax
Sweden's Ministry of Finance (MoF) has proposed amendments to the Additional Tax Act (2023:875) to implement the side-by-side arrangement agreed by the OECD Inclusive Framework on 5 January 2026. The changes aim to align Swedish law with OECD/G20
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US: IRS issues guidance on elections for business interest limitation relief, bonus depreciation exemption
The US Internal Revenue Service (IRS) issued Revenue Procedure 2026-17, which provides guidance on withdrawing elections for excepted trades or businesses under §163(j)(7) and making late elections to opt out of bonus depreciation under
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Korea (Rep.) introduces transfer pricing reforms, Pillar Two rollout
Korea (Rep.) has published Presidential Decree No. 36128, partially amending the enforcement Decree of the International Tax Adjustment Act, in the Official Gazette on 27 February 2026. The Decree introduces sweeping updates to its international tax
See MoreTaiwan: Northern Tax Bureau issues reminder on CFC rules
Taiwan’s Northern District National Taxation Bureau has issued a reminder to businesses regarding the Controlled Foreign Company (CFC) rules, which came into effect in 2023. The rules were introduced to prevent multinational enterprises from
See MoreItaly clarifies Swiss cantonal net wealth tax not creditable against CFC tax
The Italian tax authorities have issued Ruling Answer No. 70/2026, which addresses a specific tax query regarding whether a Swiss cantonal tax—the "Capital Tax"—can be deducted from the Italian taxes due under the Controlled Foreign Company
See MoreRussia reminds organisations to file 2025 CFC notifications
Russia has reminded organisations that the deadline to submit notifications on controlled foreign companies (CFCs) for 2025 expires on 20 March 2026. This announcement was made on 4 March 2026. A CFC notification must be filed regardless of
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CJEU rules Belgium non-compliant for excluding foreign tax credits under ADAT CFC framework
The Court of Justice of the European Union (CJEU) delivered a judgment on 26 February 2026, examining how Belgium has transposed the Controlled Foreign Company (CFC) rules under the Anti-Tax Avoidance Directive (ATAD). The case centred on whether
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