International updates - June 2018

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International updates - June 2018

International Updates

The latest international updates from our correspondents around the world.

Argentina: Regulations on certain tax reform aspects

Australia: Digital tax and stapled structures

Canada: Selected international tax measures from the 2018 Canadian budget

Chile: Chilean IRS interpretation of Article 12 of Chilean double tax treaties

China: New Chinese tax incentives for innovation and private pension provision

Germany: Post-BEPS challenges and transfer pricing solution requirements in central management functions

Hong Kong: Hong Kong introduces an enhanced R&D tax incentive

India: Supreme Court rules on the tax implications of loan waivers

Indonesia: New regulation issued to identify beneficial owners in support of EOI

Ireland: High Court to hear case on deductibility of foreign withholding tax

Italy: Transfer pricing framework in Italy: formal alignment to the OECD principles

Luxembourg: New opportunities for business cooperation between Luxembourg and Ukraine

Malta: Malta Budget Measures Implementation Act 2018

New Zealand: Tax credit for research and development from April 2019

Poland: New commercial property tax in Poland

Russia: Does an asset deal prevent the transfer of historical tax risks in Russia?

South Africa: The impact of the Multilateral Convention on South African investment structures involving Mauritius

Spain: Participation exemption for real estate rental entities

Switzerland: ALPS: International social security compliance in Switzerland has just gone digital

Turkey: Turkey introduces another tax amnesty

US Inbound: Sale of partnership interest

US Outbound: IRS issues APA statistics for 2017

more across site & shared bottom lb ros

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Originators, loan purchasers and securitisation vehicles may need to revisit servicing agreements and pricing after a key judgment narrowed the VAT credit management exemption
Opening doors for existing talent within Baker McKenzie and a desire for enhanced legal capabilities informed Ricardo Perera’s switch from KPMG
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