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 & bottom lb ros

More from across our site

As the firm declined to speak with ITR over its progress, senator Deborah O’Neill branded PwC Australia’s recent parliamentary responses as ‘unsatisfactory’
A Swedish company’s CEO working part-time in Denmark led to a noteworthy PE decision; in other news, Latham & Watkins grew its London tax team
Rather than outright replace human intelligence, AI solutions can serve as the ‘infinite intern’ tax advisers need to automate onerous tasks, argues Russell Gammon of Tax Systems
The lack of provision for bilateral advance pricing agreements is a notable omission from proposed reforms of Brazil’s transfer pricing rules
Ursula von der Leyen is under pressure to ensure her new team makes competitiveness a top priority. How tax policy is designed and implemented is crucial, writes Ralph Cunningham
Speaking exclusively at ITR’s Transfer Pricing Forum in Europe, the Commission’s Marc Clercx also addressed industry concerns over the arm’s-length principle
After a protracted offensive from 10 Australian professional bodies, a Senate motion to strike out contentious new tax ethical rules has failed, but concessions were secured
The closely watched decision represents the final nail in the coffin for Apple and serves as a warning to other multinationals, experts have suggested
UK tax advisers have branded Reeves’ pledge to cap corporation tax at 25% as “a smart move” and “an easy give”
In the wake of the global rankings release, we focus on the top performers across EMEA in the second of three regional analyses
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