International updates - September 2017

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International updates - September 2017

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The latest international updates from our correspondents around the world.

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

more across site & shared bottom lb ros

More from across our site

CSR initiatives can sometimes venture into virtue signalling, but Ryan’s tax literacy event for schoolchildren was a genuine and necessary endeavour
Grant Thornton advanced plans to integrate its Australian firm into its US arm, as tax developments spanned law firm hires, aviation levies and digital services taxes
A new focus on early intervention and increased AI use is transforming how tax authorities are approaching TP audits, though capacity-constrained jurisdictions risk falling behind
The French administration has used AI to detect undeclared swimming pools and verandas but always includes a human in the loop, the AI in Tax Forum heard
The UK tax authority’s deputy director of large business also reassured taxpayers that HMRC will not ‘nitpick’ returns
Sucafina’s tax chief was speaking at the ITR Pillar 2 Forum in London alongside experts from HMRC and other organisations
India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
The UK-based big four spin-off firm has hired Marc Lien, who declared that most AI in professional services today is ‘cosmetic’
Projected revenue losses and exemption requests are harming the project’s capability and viability
HMRC secured lengthy prison sentences in a major payroll VAT fraud case, while law firms announced tax promotions and hires
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