Controlled Foreign Company (CFC) Rules
1    The Income Tax Law, through a Minister of Finance Decree,      determines the time of receipt of dividend by a resident taxpayer on capital participation in a business entity abroad other than a business entity that sells its shares on a stock exchange in these cases:
·    The amount of capital participation of the resident taxpayer  is a minimum of 50% (fifty percent) of the number of paid-up shares; or
·    Jointly with other resident taxpayer(s) owns a minimum capital participation of 50% (fifty percent) of the number of paid-up shares.
2    The time of receipt of dividend by a resident taxpayer with the above conditions is as follows:
·    in the fourth (4th) month after the deadline for the submission of the Annual  Corporate Income Tax Return of the foreign entity for the  fiscal year concerned; or
·    in the seventh (7th) month after the end of a fiscal year if such foreign entity does not have any obligation to submit an Annual Corporate Income Tax Return or if there is no deadline for the submission of the Annual Corporate Income Tax Return.
3    The amount of dividend shall be the total amount of dividend that the local taxpayer is entitled to, from the profit after tax, according to its capital participation in the foreign entity other than a business entity that sells its shares on stock exchange.