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As outlined in the Presidential Address to the Federal Assembly last December, the Ministry of Finance has prepared a bill to combat the use of tax optimisation schemes whereby chains of companies are created in various jurisdictions and used in order to reduce the tax burden to the maximum possible extent when allocating the profits to the ultimate beneficiary (the “Bill”).
The Bill was published on 18 March 2014, as the first of a package of anticipated anti-offshore bills. The Bill introduces the concept of a controlled foreign company (“CFC”) to the Tax Code and imposes new requirements on taxpayers. It is expected to become effective on 1 January 2015.