Proposed amendment to the participation exemption rule
28 October 2020
The Budget measures Implementation Bill [Bill No. 173] has proposed the introduction of a new proviso to article 12(1)(u)(1) of the Income Tax Act (CAP 123) in terms of which the exemption from tax of income derived from a qualifying participating holding shall not apply to a dividend derived from a participating holding in a body of persons resident for tax purposes in a jurisdiction that is included in the EU list of noncooperative jurisdictions for a minimum period of 3 months during the year immediately preceding the year of assessment [see article 3 of Part III of the Budget Measures Implementation Bill].
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