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.