On November 5, 2026, the FTA published Circular No. 51, "Own Participation Rights."
The circular provides an explanation of the relevant statutory provisions as well as the new regulations governing the acquisition of a company’s own equity interests that have been enacted since the publication of FTA Circular No. 5 of August 19, 1999, on the 1997 Corporate Tax Reform. It also includes relevant case law from the Federal Supreme Court.
Circular No. 51 is available here.
