International updates - September 2017

Albania: Law on remission of unpaid tax and custom duties approved

Argentina: Protocol drastically changes tax treaty with Brazil

Australia: Recent developments

Brazil: Obligation to file CbC report when there is no effective competent authority agreement in place for its automatic exchange clarified; Double tax treaty with Russia now in force

Canada: Conservative approach taken to BEPS Multilateral Instrument

Chile: Life insurances with savings are subject to taxation

China: New rules promote foreign investment while tightening regulatory enforcement

Croatia: Advance pricing agreements implemented

Cyprus: Long-awaited transfer pricing guidelines on intra-group financing released

Egypt: VAT increased to 14%

Georgia: Kyrgyzstan ratifies double tax treaty with Georgia

Germany: German anti-treaty shopping rules under scrutiny

Greece: Clarifications on the tax treatment of foreign trusts and foundations

Hong Kong: Courts rule on taxability of property investments

India: Bombay High Court upholds availability of benefits under the India-Mauritius tax treaty

Indonesia: New CFC rule and new anti treaty abuse rule

Ireland: Briefing paper gives insight into Ireland’s international tax policy

Italy: Moving towards the fourth industrial revolution

Luxembourg: New BEPS-compliant IP regime to open up opportunities

Malta: Updates to the CRS guidelines

Mexico: Substance-only tax litigation proceedings introduced

Montenegro: Montenegro and US sign intergovernmental agreement to implement FATCA

New Zealand: MLI positions

Poland: Proposals will not allow investment cost deductions from operational revenue

Portugal: New VAT payment regime on import of goods

Portugal: Ruling on toll manufacturing and distribution activities and permanent establishment

Russia: The latest trends in the beneficial ownership concept

South Africa: Proposed international tax amendments

Spain: Should medics be taxed on invitations to medical seminars?

Switzerland: Swiss VAT consequences for distance selling businesses as of 2019

Turkey: A new audit mechanism: Call for justification

US Inbound: Tax court rules against IRS on tax treatment of disposition of partnership interest

US Outbound: Cancellation of APAs by IRS, abuse of discretion