The Ministry of Finance has released a revised version of the draft law regarding introduction of CFC rules. The important changes of the revised draft law are given below:
• Concepts regarding “Beneficial owner” and “actual right to receive income” are proposed.
• Further developments of Controlled foreign companies (CFC) rules. A foreign company shall be treated as a CFC during any period which begins or ends during a calendar year if a company is not a tax resident, or a company is controlled by tax residents (legal entities and/or individuals), or a company is not listed or admitted to trading on one or more stock exchanges contained in a list approved by the Central Bank.
•  Penalty for underpayment of the tax on attributed income of the CFC has reduced.
• Two types of notification responsibilities for tax residents (individuals and legal entities) are proposed related to all CFCs and foreign companies’ participation where such direct or indirect share capital participation exceeds 1%.
• Initiation of new definition of controlled debt for thin capitalization purposes.