EU: Court of justice: Non-deductibility of losses of a foreign permanent establishment
The Court of Justice of the European Union (hereinafter 'CJEU'), in its judgment in Case C-538/20 of 22 September, ruled that a Member State may deny a deduction of final losses of a permanent establishment resident in another state, where the country of residence has waived its power to tax the profits of that permanent establishment under a double taxation convention.
The Chilean Ministry of Finance recently published a preview of its tax reform project. Below is a brief summary of the main changes it would like to make:
Income tax - partial disintegration
The tax reform project refers to a 'semi-dual' system applicable to corporations, which separates the taxation of corporations and their shareholders. Corporate income tax would no longer be a credit against shareholder tax; both taxes would be added together.