The Belgian Ruling Office has granted a decision on the new CFC regime
Last week, the Belgian Ruling Office granted an advanced tax decision (not published yet) recognising the non-application of the upcoming Belgian CFC (‘Controlled Foreign Company’) law for two foreign companies owned by a Belgian parent company. Salient points of this decision This advance tax decision covering the inapplicability of the CFC regime is of particular
Brazil enacts new rules impacting dividend withholding, interest deductions, goodwill amortization and CFCs
The Brazilian government on May 14, 2014 enacted Law No. 12.973/2014, converting into law Provisional Measure 627/2013 (PM 627). The key provisions of the enacted law are the revocation of the Transitional Tax Regime (RTT) and new rules regarding the treatment of dividends, interest on net equity (INE), amortization of goodwill, and controlled foreign corporations
