Legislative Tracking in Focus

Autumn tax amendments: withholding tax

As we continue to update you on the changes introduced by a recent major tax package, this publication highlights the changes in the treatment of withholding tax:
  • the law introduces a new type of passive income ― intragroup service fees;
  • secondary adjustments made under transfer pricing rules in controlled transactions with non-residents will be treated as dividends;
  • there will be a transitional period when the taxpayers will still be able to claim benefits offered by the suspended tax treaties.