• A 50% withholding tax on interest, dividends and royalties paid to tax haven residents
• Non-deductibility of certain payments to tax haven residents unless the payer justifies the genuine and reasonable nature of the payment
• The settlement of the participation exemption would not be applicable on dividends received from tax haven
• The controlled foreign company rules will be restricted in relation to the minimum participation threshold, or the foreign low-tax description, or the economic activity protection test, or all.