International updates - June 2017

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

International updates - June 2017

intl-updates-large.jpg

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 ever-expansive firm has once again attracted a former ‘big four’ talent to lead the new offering
The amended double taxation avoidance agreement removes France’s most favoured nation status for tax treaty benefits
The levies extended beyond the president’s ‘legitimate reach’, the Supreme Court ruled
While Brazil’s consumption tax overhaul led to a short-term spike in tax advisory demand, we are now in a period of ‘normalisation’ marked by decreased recruitment
The expanded firm will comprise roughly 8,500 employees, including 550 partners; in other news, Paul Hastings and Macfarlanes made senior tax hires
Meanwhile, one expert highlights the importance of separating Venezuela’s tax authority from direct political control after ‘lost decades and isolation’
With PMK 108, Indonesia has upgraded its tax transparency regime for the digital era, focusing on data quality, governance, and cross border exchange rather than expanding regulatory reach
In a popular LinkedIn post, Jeremie Beitel encouraged firms to invest in junior talent even if it doesn’t lead to their loyalty, though recruiters offered ITR a mixed assessment
Advisers who do not register for the new regime in time could be prevented from interacting with HMRC, the tax authority said
Valid pillar two objectives are still intact after the side-by-side agreement, but whether the framework is now settled is ‘a $64,000 question’, Morrison Foerster’s tax chair told ITR
Gift this article