International updates - June 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