International updates - May 2016

April 29 2016

The latest international updates from our correspondents around the world.

Albania: IMF requests amendments to Albanian property tax

Australia: Australian BEPS update pre-election

Brazil: Brazil’s Senate approves Convention on Mutual Administrative Assistance in Tax Matters

Canada: Federal Court of Appeal agrees with TDL on scope of Canadian interest deductibility purpose test

Chile: Change of scenery: Chilean tax assistance and transparency

China: China’s new VAT rates and rules across all industries

Croatia: Treaty analysis: Croatia-Luxembourg DTA enters into force

Cyprus: Recent developments in Cypriot IP taxation: Are you prepared?

EU: EU Commission proposes public CbCR

Germany: EGC rules German exception to change-in-ownership rule qualifies as unlawful state aid

India: Taxing digital transactions in India

Indonesia: Indonesia targeting cross-border and online transactions

Ireland: New Irish tax appeals system

Italy: Italian Revenue Agency issues guidelines on LBOs

Luxembourg: Luxembourg VAT: CJEU delivers important decision regarding real estate investment funds

Poland: Incoming reporting changes in Poland

Russia: Transfer pricing audits in Russia: Initial results and trends

Serbia: Treaty analysis: Serbia ratifies DTA with South Korea

South Korea: Tax Tribunal rules Korean tax authority had no basis to disregard the existence of domestic holding companies established to facilitate LBO

Spain: Spanish Supreme Court confirms that Brazilian ‘juros sobre o capital próprio’ can benefit from Spanish participation exemption regime

Switzerland: Swiss perspective: Standardised electronic format for the exchange of CbC reports released by the OECD

US Inbound: US proposes new debt-equity regulations regarding interest in a corporation

Topics

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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