The amendments to the Corporate Income Tax Law were published on 3 November 2015, in the Official Gazette No. 83/2015. The Law entered into force on 4 November 2015.
The amendments to the Corporate Income Tax Law include:
– Implementation of Council Directive 2014/86/EU amending the Parent-Subsidiary Directive (recast) (2011) (PSD). The PSD imposes limitations to the dividend participation exemption regarding hybrid financial instruments.
– Implementation of Council Directive 2015/121 amending the PSD. The exemptions under the PSD will no longer be granted when the main purpose or one of the main purposes of the arrangement is to obtain tax advantages; and
– Amendments to the Corporate Income Tax Law regarding actuarial gains or losses that are not recognized in the profit and loss account under the amended International Accounting Standard (IAS) 19 (employee benefits). Employee benefits are generally subject to a special tax rule where 50% of the provisions for employee benefits are allowed as deductions from the taxable base. Based on the amendments, actuarial gains and losses will be subject to the same rules.
