01
Document overview
Current Participation Exemption and foreign-PE exemption rules covering ownership interests, aggregation, the 9% subject-to-tax test, asset test, liquidation losses and recapture.
- Applies to periods from 2025.
- Includes a 9% subject-to-tax test.
- Earlier periods require a separate historical version.
02
Scope and exclusions
Applies to
Applies to tax periods beginning on or after 1 January 2025 where the Participation Exemption or foreign-PE election is used.
Limitations and exclusions
MD 116/2023 remains the historical version for earlier periods; the exemption does not apply unless ownership, holding-period, subject-to-tax and other conditions are met.
05
Official primary source
Ministerial Decision No. 302 of 2024
Verify official text ↗