The Finance Ministry (MoF) has issued a Letter No. 03-01-23/30779 on 27th May 2016 for clarifying the responsibility of taxpayers to notify the tax authorities about CFCs. On the basis of section 3.1 of article 23 of the Tax Code, taxpayers have to notify the tax authorities regarding CFCs in relation to which they are recognized as controlling persons and this notification need to be submitted by 20 March of the year following the year. Here, CFC’s profits have to be included in the controlling company’s taxable base. Also, the MoF described that the Tax Code does not state the minimum income amount to be received by the controlling person in the form of the CFC’s profits due to the notification of the tax authorities.
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PGA Highlights: July 2016
PGA Highlights: July 2016
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