WebUnder Korea’s thin capitalization rule, where a Korean company borrows from its foreign controlling shareholder an amount in excess of three times its equity (six times in the … Web15 Jul 2024 · Thin capitalization occurs when companies finance investments and operations through a level of debt far higher than their level of equity. High- tax countries …
The Corporate Tax Planning Law Review: South Korea
Web3 Feb 2024 · A shareholder loan extended by a foreign parent company to its Korean subsidiary, however, is subject to the thin capitalisation rule, whereby any interest paid on the shareholder loan in excess ... Web1 Nov 2024 · Under the South Korean thin capitalisation rules, where a South Korean company borrows from its foreign controlling shareholders (FCS), interest relating to FCS … green auto rickshaw
Kenya Tax Alert - Finance Bill, 2024 - Deloitte
Web15 Dec 2024 · Although the tax law specifies the standard useful lives for each type of assets, the useful life of a fixed asset can be increased or decreased by 25% of the … Web5 May 2024 · Introduction of an EBITDA-based interest limitation rule to replace the thin capitalisation interest limitation rule The measure The Bill proposes to delete Section 16(2)(j) of the Income Tax Act, which prohibits a foreign controlled entity from claiming a deduction of interest in excess of the debt-to-equity ratio of 3:1. In cases where a Korean company borrows from its foreign-controlling shareholder and the debt-to-equity ratio exceeds 2:1 (6:1 in case of financial institutions), a portion of interest payable on the excess borrowing is characterised as dividends subject to Korean WHT (reduced rate if a tax treaty applies) while … See more The LCITA authorises the tax authorities to adjust the transfer price based on an arm’s-length price and to determine or recalculate the taxable income of a … See more Under the Korean CFC rule, when a Korean national directly or indirectly owns at least 10% in a foreign corporation and the foreign company’s average effective … See more In a commitment to implement the hybrid mismatch rules recommended by the OECD (BEPS Action 2), a new rule shall limit expense deductions for hybrid mismatch … See more Under the provision of the CITL, the tax authorities may recalculate the corporation’s taxable income when CIT is unreasonably reduced due to transactions with … See more flowers dianthus perennial