CFC legislation – main amendments effective from 1 January 2014

On 23 December 2013, the parliament approved amendments to the controlled foreign company (CFC) legislation, which are effective from 1 January 2014 (i.e. Amendment 198 to the 1961 Income Tax Ordinance "ITO"), which includes modifications to section 75B of the ITO). The main amendments are as follows.

CFC foreign tax threshold
Foreign companies may be qualified as CFC companies when their passive income is subject to tax at a rate lower than 15% (previously, 20%).

Passive i…