Corporate - Significant developments

Last reviewed - 24 June 2022

The anti-avoidance rules on dividend income and capital gains apply as follows:

  • Dividend income and capital gains deriving from investments in foreign legal entities are not tax-exempt for income tax purposes if more than 50% of the total income of the foreign legal entity consists of passive income and its taxable income is subject, directly or indirectly, to low taxation.
  • For participations owned before 1 January 2019, the anti-avoidance rules did not apply if a dividend income or capital gain was realised before 31 December 2021. As of 1 January 2022, regular anti-avoidance rules apply to such participations.