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

Topics

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Direct Tax

Alex Cobham, Paul Monaghan

Tax campaigners clash on pillar two as side-by-side deal costs emerge

Despite estimates that the US/OECD agreement will cost countries billions, the Fair Tax Foundation’s Paul Monaghan believes the deal is a ‘necessary evil’

Sam Sholli, March 16 2026

Direct Tax

A taxing week: WTS enters fierce battle for global tax advisory supremacy

The firm’s eye-catching UK launch is a major statement of intent, but it will face stern opposition in its quest to be the top global tax player

Tom Baker, March 13 2026

Direct Tax

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

This week in tax: HMRC defers tax agent registration for financial services businesses

The postponement came after industry representatives flagged implementation issues with the registration regime; in other news, firms made key tax partner additions

Sam Sholli, March 13 2026

Transfer Pricing

HMRC almost doubles revenue from TP cases in one year

Despite the increased yield, the time taken to resolve enquiries was at a six-year high, new HMRC statistics have revealed

Sam Sholli, March 12 2026

Direct Tax

High court 2000.jpg

Dan Neidle defeats £8m libel claim brought by ‘tax avoidance promoter’

The High Court’s dismissal of barrister Setu Kamal’s legal challenge represents the first successful strike-out under a new law on SLAPPs

Sam Sholli, March 11 2026

Indirect Tax

US tariffs

Opinion: Tariff turbulence is a wake-up call for IP attorneys

IP lawyers, who say they are encouraging clients to build up ‘tariff resilience’, should treat the risks posed by recent orders as a core consideration in cross-border licensing

Sanjana Mishra, March 11 2026

Transfer Pricing

Coca-cola

Is Coca-Cola’s ‘Black Swan’ event in sight?

As Coca-Cola awaits a crucial 11th Circuit Court of Appeals decision this year, its multibillion-dollar tax dispute could have profound implications for investors, cash flow, and corporate transparency

Alex Martin, March 10 2026

Direct Tax

Gender equality

Gender equality has improved ‘significantly’: 79% of female tax advisers

However, women in tax face greater career obstacles than their male counterparts, an exclusive ITR survey of more than 100 women tax leaders revealed

Tom Baker, March 09 2026

Direct Tax

jeff soar resized.jpg

Former EY tax leader spearheads WTS UK launch

Under Jeff Soar’s leadership, WTS UK aims to scale to 100 partners within five years and challenge the big four

Tom Baker, March 09 2026

Direct Tax

A taxing week: Deloitte’s culture is about to face a tough test

As the firm embarks on a major shakeup of its EMEA partnerships, some staff will be watching nervously

Ed Conlon, March 06 2026