International updates - June 2017

June 01, 2017

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

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Leanna Reeves, June 23, 2022

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Companies urged to pause Northern Ireland supply chain changes

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Close-up of a woman's ear and hand through a torn hole in the paper. Yellow background, copy space. The concept of eavesdropping, espionage, gossip and tabloids.

Taxpayers still rely on market whispers to manage risk

Tax leaders say communication with peers is important for risk management, especially on how to approach regional authorities.

Danish Mehboob, June 20, 2022

Magnifying glass close up with world map

In-house hunt for technologists amid digitalisation

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Danish Mehboob, June 20, 2022

McDonald’s to pay €1.25bn to settle French tax evasion case

The US fast-food company has agreed to pay €1.25 billion to settle the French investigation into its transfer pricing arrangements over allegations of tax evasion.

Leanna Reeves, June 17, 2022

This week in tax: HMRC delays pillar two adoption

HM Revenue and Customs said the UK pillar two legislation will be delayed until at least December 2023, while ITR reported on a secret Netflix settlement and an IMF study on VAT cuts.

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