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 & shared bottom lb ros

More from across our site

Wim Wuyts, who had been head of the specialist tax network since 2017, is moving on to a new role with WTS’s Belgian member firm
MNEs are increasingly using algorithmic tools in TP. Sahasranshu Dash argues that data ethics should therefore plug directly into the TP design process
The Institute of Chartered Accountants in England and Wales also queried whether HMRC resources could be better spent scrutinising larger entities
Grant Thornton’s Austria tax head likens his practice to an escape room, shares his football coaching ambitions, and explains why tax is cool
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2025 EMEA Tax Awards
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2025 Asia-Pacific Tax Awards
The fates of pillars one and two hang in the balance after the US successfully threw its weight around in G7 and Canadian negotiations
Rafael Tena tells ITR about the ‘crazy’ Mexican market, ditching the hourly rate, and refusing to grow his fledgling firm in an ‘unstructured way’
It should be easy for advisers to be transparent about costs, Brown Rudnick partner Matthew Sharp said in response to exclusive ITR in-house data
The sprawling legislation phases out Joe Biden-era green tax incentives for businesses; in other news, the UK will reportedly maintain its DST despite US pressure
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