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
See More
Australia: ATO targets thin capitalisation in trust reviews
The Australian Taxation Office (ATO) has announced on 30 January 2025 regarding its focus on the updated thin capitalisation rules as part of its justified trust reviews. Thin capitalisation in focus for justified trust reviews How we're
See More
Indonesia updates CRS participating and reportable jurisdictions for 2025
Indonesia's Directorate General of Taxes has published Announcement No. 1/PJ/2025 on 24 January 2025, listing the participating and reportable jurisdictions for the 2025 automatic exchange of financial account information under the Common Reporting
See More
Italy announces qualified jurisdictions for supplementary, national minimum tax
Italy’s Ministry of Economy and Finance has published a list of jurisdictions, on 23 January 2024, that have enacted supplementary minimum tax and national minimum tax laws. These jurisdictions have obtained the transitional “qualified” status
See More
Ecuador updates tax haven and preferential regime guidelines
Ecuador's Internal Revenue Service (SRI) has published Circular NAC-DGECCGC25-00000002 on 21 January 2025, outlining new guidelines for identifying tax havens, preferential tax regimes, and low-tax jurisdictions. A regime or or jurisdictions
See More
Taiwan updates low-tax jurisdictions list
Taiwan's Ministry of Finance (MOF) released an updated list of low-tax jurisdictions on 27 December 2024. Controlled Foreign Company (CFC) rules, which have been in effect in Taiwan since the 2023 tax year, were introduced to prevent companies or
See More
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
See More
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
See More
Australia: ATO consults implementation of thin capitalisation third-party debt test
The Australian Taxation Office (ATO) has initiated a public consultation regarding the implementation of the thin capitalisation third-party debt test . Additionally, it addresses the associated Schedule 3 of Draft Practical Compliance Guideline
See More
Belgium publishes guidance on new CFC rules
Belgium’s tax authorities have issued two circular letters - Circular 2024/C/82 and Circular 2024/C/83 - on 13 December 2024 - providing clarity on specific aspects of the controlled foreign company (CFC) rules introduced in 2023. The amended
See More
Austria updates CFC rules to prevent double taxation under Pillar Two
Austria's parliament has amended its CFC rules to avoid double taxation issues under the Pillar Two global minimum tax framework. Amendments to Section 10a of the Austrian Corporate Income Tax Act have been approved and now require Qualified
See More
Slovenia proposes changes corporate income tax law
Slovenia's government has presented a draft bill (EVA: 2024-1611-0039) to the parliament on 25 October 2024, proposing several amendments to the corporate income tax law. Tax loss carry-forward limitation The bill suggests limiting the
See More
New Zealand introduces tax policy work programme
New Zealand’s Minister of Revenue has introduced a tax policy work programme on 13 November 2024, which aims to simplify tax and reduce compliance costs, address integrity risks, and improve fiscal sustainability to rebuild the economy. The
See More
Philippines streamlines tax treaty rules for government securities
The Philippines Bureau of the Treasury (BTr) announced in a press release on 5 November 2024 the implementation of a streamlined tax treaty procedure for non-resident investors in Government Securities (GS). This initiative is part of the
See More
Colombia: DIAN mandates certification for third-party debts under thin capitalization rules
The Colombian tax authority (DIAN) issued Ruling 803 of 23 September 2024, released on 1 November 2024, which provides guidance on the necessary certification of third-party debts for interest deduction purposes under the thin capitalization
See More
Czech Republic updates list of non-cooperative CFC jurisdictions
The Czech Republic Ministry of Finance has released Financial Bulletin No. 9/2024, containing a notice regarding the lists of non-cooperative jurisdictions for various periods about the Czech Republic's controlled foreign company (CFC)
See More
Australia: ATO issues guidance on thin capitalisation rules, related provisions
The Australian Taxation Office (ATO) released guidance on 3 November 2024, outlining how the thin capitalisation rules interact with other provisions. The thin capitalisation rules limit the amount of debt deductions you can claim. Regard must
See More
US: IRS and Treasury Plan to Issue Guidance on Streamlined Approach to Baseline Distribution Activities
In the IRS and Treasury Priority Guidance Plan for 2024/25, issued on 3 October 2024, there is a plan for a new section 482 guidance project to provide guidance for taxpayers consistent with Amount B of Pillar One. The OECD Amount B Guidance
See More