International updates - July/August 2016

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International updates - July/August 2016

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The latest international updates from our correspondents around the world.

Argentina: Tax amnesty and developments sent to Congress

Brazil: Computer software included in the concept of copyrights for the purposes of the double tax convention between Brazil and Finland

Canada: Important Deadline Approaching under Canada’s “upstream loan” Rules

Chile: Entry into force regime for Chile’s General Anti-Avoidance Rule

Chile: Understanding the new employee stock option plans

Cyprus: Cyprus immovable property tax reform

Germany: Draft tax law includes BEPS measures including CbCR requirements

Greece: Treaty analysis: Greece-Cyprus DTT tax credit mechanism relating to dividend payments

India: Renegotiation of tax treaties by India

Indonesia: New tax amnesty law and real estate investment funds in Indonesia

Ireland: Guidance published on secondary reporting mechanism for CbC reporting

Italy: Advance ruling for new investments in light of the recent clarifications provided by tax authorities

Luxembourg: Crowdfunding in the EU: VAT consequences

New Zealand: Changes coming for employee share schemes

Norway: Foreign shareholders face 10-year withholding tax reassessments after Supreme Court ruling

Poland: GAAR comes into force in Poland

Russia: Companies must comply with new waste rules or face environmental tax

Serbia: Serbia clarifies registration of foreign entities for VAT purposes

South Korea: Recent ruling clarifies whether foreign limited partnership can be looked through for purposes of treaty application

Spain: Participation exemption in ‘pure holding companies’

Switzerland: Swiss parliament approves Corporate Tax Reform III

US Inbound: Medtronic wins US transfer pricing case

more across site & shared bottom lb ros

More from across our site

The threat of 50% tariffs on Brazilian goods coincides with new Brazilian legal powers to adopt retaliatory economic measures, local experts tell ITR
The country’s chancellor appears to have backtracked from previous pillar two scepticism; in other news, Donald Trump threatened Russia with 100% tariffs
In its latest G20 update, the OECD also revealed tense discussions with the US where the ‘significant threat’ of Section 899 was highlighted
The tax agency has increased compliance yield from wealthy individuals but cannot identify how much tax is paid by UK billionaires, the committee also claimed
Saffery cautioned that documentation requirements in new government proposals must be limited if medium-sized companies are not exempted from TP
The global minimum tax deal is not viable without US participation, Friedrich Merz has argued
Section 899 of the ‘one big beautiful’ bill would have spelled disaster for many international investors into the US, but following its shelving, attention turns to the fate of the OECD’s pillars
DLA Piper’s co-head of tax for the US and Latin America tells ITR about her fervent belief in equal access to the law, loving yoga, and paternal inspirations
Tax expert Craig Hillier agrees with the comparison of pillar two to using a sledgehammer to crack a nut
The amount is reported to be up 57% from the £5.6bn that the UK tax agency believes was underpaid in the previous year
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