The Ministry of Finance on 20 May 2013 published a draft law on modifications to the taxation of companies. The proposal does not implement the previous plan of a further reduction in tax rates to 15 percent and instead proposes that the 17 percent tax rate should remain.
In connection with the transfer pricing rules the Ministry proposes to expand the definition of related persons to include sister companies, these being companies that are both related to the same shareholder. The shareholder (individual or company) has to hold directly or indirectly at least 25% of shares or voting rights in the subsidiaries according to the proposed law.
Also the thin capitalization rules need to be amended to make the calculation of average equity more straightforward.
