International updates - June 2017

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International updates - June 2017

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The latest international updates from our correspondents around the world.

Brazil: Tax authorities issue guidance on the treatment of software as a service

Canada: Broadening the de facto control test could impact cross-border transactions

Chile: Concept of beneficiary of a double tax treaty

China: First tax case decision by Chinese Supreme Court

Germany: Finance Ministry issues guidance on the use of a brand name within a multinational group

Greece: Administrative guidelines published on tax benefits of cross-border restructurings

India: Important Supreme Court decisions on tax

Indonesia: Will the amendments to the Income Tax Law simplify the rules?

Ireland: Ireland’s cooperative compliance framework

Italy: New revision of the Italian Transfer pricing provisions on arm’s length principle

Malta: Incentives for Malta’s capital markets

New Zealand: Courts consider challenge to information requests issued at request of foreign tax authority

Norway: Proposed interest limitation rules may impact inbound investments

Poland: The benefits of operating in a special economic zone

Romania: Tax Incentives for companies performing research and development activities

Russia: Bilateral APAs with Russia offer new opportunities

South Africa: SARS confirms zero dividends tax rate in Swedish-South Africa DTA

Spain: Would EU law preclude Spanish inheritance and gift tax legislation in relation to cases involving parties resident in third states?

Switzerland: The impact of currency fluctuations on the CbCR threshold

Turkey: New tax amnesty to be introduced

US Inbound: New IRS APA report shows significant decrease in APA requests

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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