New rules relating to controlled foreign companies and other low-taxed income

The fourth tax package published on 19 December 2016 completely redefines the rules of controlled foreign companies and the system of sanctions applied against them. The amendments will take effect on the 30th day following promulgation (18 January 2017); however, taxpayers may choose the application of the new rules as early as in the 2016 tax year. The rules conform to the European Union’s anti-tax avoidance recommendations, but the rapid introduction makes it almost impossible to prepare for the changes.