Azerbaijan Increases Effective Corporate Tax Threshold for CFC Rules

According to recent reports, Azerbaijan has amended its controlled foreign company rules with an increase in the effective corporate tax threshold from 50% to 75% of the Azerbaijan tax that would be payable. As such, foreign companies will be recognized as a CFC of an Azerbaijan resident company if:

• The resident, together with associated companies, directly or indirectly holds a participation of more than 50% in the foreign company's capital, voting rights, or rights to profits;
• The effectiv…