International updates - June 2018

June 19 2018

International Updates

The latest international updates from our correspondents around the world.

Argentina: Regulations on certain tax reform aspects

Australia: Digital tax and stapled structures

Canada: Selected international tax measures from the 2018 Canadian budget

Chile: Chilean IRS interpretation of Article 12 of Chilean double tax treaties

China: New Chinese tax incentives for innovation and private pension provision

Germany: Post-BEPS challenges and transfer pricing solution requirements in central management functions

Hong Kong: Hong Kong introduces an enhanced R&D tax incentive

India: Supreme Court rules on the tax implications of loan waivers

Indonesia: New regulation issued to identify beneficial owners in support of EOI

Ireland: High Court to hear case on deductibility of foreign withholding tax

Italy: Transfer pricing framework in Italy: formal alignment to the OECD principles

Luxembourg: New opportunities for business cooperation between Luxembourg and Ukraine

Malta: Malta Budget Measures Implementation Act 2018

New Zealand: Tax credit for research and development from April 2019

Poland: New commercial property tax in Poland

Russia: Does an asset deal prevent the transfer of historical tax risks in Russia?

South Africa: The impact of the Multilateral Convention on South African investment structures involving Mauritius

Spain: Participation exemption for real estate rental entities

Switzerland: ALPS: International social security compliance in Switzerland has just gone digital

Turkey: Turkey introduces another tax amnesty

US Inbound: Sale of partnership interest

US Outbound: IRS issues APA statistics for 2017

Topics

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Indirect Tax

Brazil tax money

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

Direct Tax

germany berlin reichstag building german parliament bundestag - Concept piece for power, authority, economy, performance, government, planning and control.

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

Direct Tax

OECD image.jpeg

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

Direct Tax

Big Ben at golden hour

Too many HMRC compliance investigations last too long, committee warns

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

Sam Sholli, July 17 2025

Transfer Pricing

UK TP proposals could ‘double compliance costs’, tax firm warns

Saffery cautioned that documentation requirements in new government proposals must be limited if medium-sized companies are not exempted from TP

Tom Baker, July 16 2025

Direct Tax

OECD image.jpeg

Pillar two no longer has a future, German chancellor claims

The global minimum tax deal is not viable without US participation, Friedrich Merz has argued

Sam Sholli, July 16 2025

Direct Tax

Pillar two is revising global tax competition with a 15% minimum tax rate

Future of pillar two uncertain after Section 899 withdrawal averts ‘catastrophe’

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

Ralph Cunningham, July 16 2025

Direct Tax

amory_heine resized.jpg

‘Pro bono is a must’: Amory Heine on giving back

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

July 15 2025

Direct Tax

Hillier, Craig_ColorPortrait.jpg

‘Huge, complex’ pillar two system encroaches on sovereignty: EY tax leader

Tax expert Craig Hillier agrees with the comparison of pillar two to using a sledgehammer to crack a nut

Sam Sholli, July 14 2025

Direct Tax

London- HM Revenue and Customs building on Whitehall, UK Governm

HMRC believes US companies underpaid £8.8bn in tax: accountancy group

The amount is reported to be up 57% from the £5.6bn that the UK tax agency believes was underpaid in the previous year

Sam Sholli, July 14 2025