International updates - July/August 2016

July 19 2016

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

Topics

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More from across our site

Transfer Pricing

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TP and the Corporate Tax Roadmap: reform by momentum, not revolution

Nearly two years after its publication, the Corporate Tax Roadmap is reshaping the UK’s TP framework through incremental reforms focused on scope, transparency and earlier HMRC intervention

Devon Buffoni, May 07 2026

Direct Tax

Audit And Fraud Investigation. Auditor Using Magnifying Glass

Pillar two’s first compliance test: what advisers should be telling clients

With a stark divergence between MNEs that prepared early and those rushing to catch up, advisers must remain agile with all manner of compliance risks

Akashni Ashok Latchanna, May 06 2026

Indirect Tax

European Union flag against European Parliament

This month in indirect tax: EU steps up VAT fraud crackdown

The EU agreed new cooperative and investigative measures to tackle VAT fraud, while Hungary faced legal action and Lavez Coutinho expanded its indirect tax team

Tom Baker, May 06 2026

Direct Tax

Aerial view of Christ and Botafogo Bay from high angle.

SiqueiraCastro acquires three-partner tax team to establish full-service Brazilian practice

The arrival of a team from Brazilian rival Costa Tavares Paes Advogados brings SiqueiraCastro’s tax headcount to seven partners and 30 associates

Tom Baker, May 05 2026

Direct Tax

ryan london zoo initiative .jpeg

A taxing week: Ryan’s day at the zoo was more than animalistic self-promotion

CSR initiatives can sometimes venture into virtue signalling, but Ryan’s tax literacy event for schoolchildren was a genuine and necessary endeavour

Tom Baker, May 01 2026

Direct Tax

Grant Thornton.jpg

This week in tax: Grant Thornton extends consolidation drive to Australia

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

Tom Baker, May 01 2026

Transfer Pricing

Africa

TP audits are moving upstream, but can African authorities keep pace?

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

Akashni Ashok Latchanna, April 30 2026

Direct Tax

AI in Tax Forum 2026.JPG

French tax authority leads way in AI adoption

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

Ed Conlon, April 29 2026

Direct Tax

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HMRC invites taxpayers to stress-test pillar two filings in ‘private beta’

The UK tax authority’s deputy director of large business also reassured taxpayers that HMRC will not ‘nitpick’ returns

Tom Baker, April 28 2026

Direct Tax

David Beringer, Sucafina, ITR P2 Forum 2026.JPG

Pillar two a ‘box-ticking’ exercise, admits MNE tax head

Sucafina’s tax chief was speaking at the ITR Pillar 2 Forum in London alongside experts from HMRC and other organisations

Ed Conlon, April 28 2026