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International updates - June 2017

01 June 2017

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The latest international updates from our correspondents around the world.

Brazil: Tax authorities issue guidance on the treatment of software as a service

Canada: Broadening the de facto control test could impact cross-border transactions
Chile: Concept of beneficiary of a double tax treaty

China: First tax case decision by Chinese Supreme Court

Germany: Finance Ministry issues guidance on the use of a brand name within a multinational group

Greece: Administrative guidelines published on tax benefits of cross-border restructurings

India: Important Supreme Court decisions on tax

Indonesia: Will the amendments to the Income Tax Law simplify the rules?

Ireland: Ireland’s cooperative compliance framework

Italy: New revision of the Italian Transfer pricing provisions on arm’s length principle

Malta: Incentives for Malta’s capital markets

New Zealand: Courts consider challenge to information requests issued at request of foreign tax authority

Norway: Proposed interest limitation rules may impact inbound investments

Poland: The benefits of operating in a special economic zone

Romania: Tax Incentives for companies performing research and development activities

Russia: Bilateral APAs with Russia offer new opportunities

South Africa: SARS confirms zero dividends tax rate in Swedish-South Africa DTA

Spain: Would EU law preclude Spanish inheritance and gift tax legislation in relation to cases involving parties resident in third states?

Switzerland: The impact of currency fluctuations on the CbCR threshold

Turkey: New tax amnesty to be introduced

US Inbound: New IRS APA report shows significant decrease in APA requests






International Tax Review Profile

RT @BrigitteAlepin: So proud of the new book WINNING THE TAX WARS. Bringing together well-known tax experts, this book presents outstanding…

Dec 7 2017 04:08 ·  reply ·  retweet ·  favourite
International Tax Review Profile

REVEALED: The top 10 of ITR's #GlobalTax50 2017 is out now. Find it here: https://t.co/IXiaRrE3vH (subscription or free trial required)

Dec 7 2017 01:42 ·  reply ·  retweet ·  favourite
International Tax Review Profile

ITR has opened the submissions period for the European Tax Awards 2018. Full details here: https://t.co/WKBWijhBgt

Dec 6 2017 01:40 ·  reply ·  retweet ·  favourite
International Tax Review Profile

@aloysrigaut @AuroChardon @ElodieLamer @JeanComte @diego_bxl @bsmithmey @afpfr @pierremoscovici @EU_Taxud @EU2017EE… https://t.co/oS4sDvQtdL

Dec 5 2017 04:55 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @AuroChardon: Is this it? https://t.co/O1XhoWQw2F 17 #taxhavens, mostly tiny countries or emerging economies on the #EUblacklist? ❌Swit…

Dec 5 2017 02:25 ·  reply ·  retweet ·  favourite
International Correspondents