International updates - June 2018

June 19 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

Topics

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More from across our site

Direct Tax

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Holland & Knight tops the hiring charts again: ITR’s half-year Talent Tracker data

ITR’s data has highlighted the US firm’s ambition to become America’s ‘premier’ tax player via a concerted partner recruitment strategy

Tom Baker, July 25 2025

Direct Tax

jakarta-indonesia 600 x 375

This week in tax: A&M Tax launches Indonesia practice with ex-KPMG managing director

Jaap Zwaan’s arrival continues a recent streak of A&M Tax investing in the region; in other news, the US and Japan struck a deal that significantly lowered tariff rates

Tom Baker, July 25 2025

Transfer Pricing

Who gets taxed when no one’s there? AI, presence, and profit allocation

In a world where international tax concepts rely on human activity, Leonard Wagenaar poses existential questions about the future of such ideas when AI is ever-present

Leonard Wagenaar, July 24 2025

Transfer Pricing

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French TP case highlights transaction scrutiny trend: experts

France v Axa provides a practical illustration of how the burden of proof is applied in TP matters under French law, ITR also heard

Sam Sholli, July 24 2025

Direct Tax

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US corporate investors back PCbCR despite government snub: FACT director

In an exclusive interview with ITR, Ian Gary calls for a central public CbCR database and bemoans the US’s lack of involvement in international tax transparency

Tom Baker, July 23 2025

Direct Tax

Reckitt

Kirkland, Slaughter and May tax teams enlisted for $4.8bn Reckitt deal

Reckitt Benckiser is to divest its Essential Home business, which includes more than 70 brands, to private equity firm Advent International

Tom Baker, July 21 2025

Direct Tax

Europe USA negotiations

A taxing week: OECD can’t fool me over US pillar two deal

In the first of a new series of weekly opinion pieces, ITR Editor Tom Baker reflects on the OECD’s attempts to sanitise the US’s brazen pillar two negotiations

Tom Baker, July 21 2025

Indirect Tax

Brazil tax money

Advisers hope Brazil and US reach agreement on Trump tariffs

The threat of 50% tariffs on Brazilian goods coincides with new Brazilian legal powers to adopt retaliatory economic measures, local experts tell ITR

Sam Sholli, July 18 2025

Direct Tax

germany berlin reichstag building german parliament bundestag - Concept piece for power, authority, economy, performance, government, planning and control.

This week in tax: Germany still ‘committed’ to pillar two despite chancellor’s condemnation

The country’s chancellor appears to have backtracked from previous pillar two scepticism; in other news, Donald Trump threatened Russia with 100% tariffs

Tom Baker, July 18 2025

Direct Tax

OECD image.jpeg

OECD unveils pillar two safe harbour for highly taxed MNEs

In its latest G20 update, the OECD also revealed tense discussions with the US where the ‘significant threat’ of Section 899 was highlighted

Tom Baker, July 17 2025