International updates - September 2017

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International updates - September 2017

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The latest international updates from our correspondents around the world.

Albania: Law on remission of unpaid tax and custom duties approved

Argentina: Protocol drastically changes tax treaty with Brazil

Australia: Recent developments

Brazil: Obligation to file CbC report when there is no effective competent authority agreement in place for its automatic exchange clarified; Double tax treaty with Russia now in force

Canada: Conservative approach taken to BEPS Multilateral Instrument

Chile: Life insurances with savings are subject to taxation

China: New rules promote foreign investment while tightening regulatory enforcement

Croatia: Advance pricing agreements implemented

Cyprus: Long-awaited transfer pricing guidelines on intra-group financing released

Egypt: VAT increased to 14%

Georgia: Kyrgyzstan ratifies double tax treaty with Georgia

Germany: German anti-treaty shopping rules under scrutiny

Greece: Clarifications on the tax treatment of foreign trusts and foundations

Hong Kong: Courts rule on taxability of property investments

India: Bombay High Court upholds availability of benefits under the India-Mauritius tax treaty

Indonesia: New CFC rule and new anti treaty abuse rule

Ireland: Briefing paper gives insight into Ireland’s international tax policy

Italy: Moving towards the fourth industrial revolution

Luxembourg: New BEPS-compliant IP regime to open up opportunities

Malta: Updates to the CRS guidelines

Mexico: Substance-only tax litigation proceedings introduced

Montenegro: Montenegro and US sign intergovernmental agreement to implement FATCA

New Zealand: MLI positions

Poland: Proposals will not allow investment cost deductions from operational revenue

Portugal: New VAT payment regime on import of goods

Portugal: Ruling on toll manufacturing and distribution activities and permanent establishment

Russia: The latest trends in the beneficial ownership concept

South Africa: Proposed international tax amendments

Spain: Should medics be taxed on invitations to medical seminars?

Switzerland: Swiss VAT consequences for distance selling businesses as of 2019

Turkey: A new audit mechanism: Call for justification

US Inbound: Tax court rules against IRS on tax treatment of disposition of partnership interest

US Outbound: Cancellation of APAs by IRS, abuse of discretion

more across site & shared bottom lb ros

More from across our site

The US’s GILTI regime will not be forced upon American multinationals in foreign jurisdictions, Bloomberg has reported; in other news, Ropes & Gray hired two tax partners from Linklaters
APAs should provide a pragmatic means to agree to an arm's-length outcome for an Australian entity and for the ATO, the tax authority said
Overall revenues and average profit per partner also increased in the UK, the ‘big four’ firm revealed
Increasingly complex reporting requirements contributed towards the firm’s growth in tax, it said
Sector-specific business taxes, private equity tax treatment reform and changes to the taxation of non-residents are all on the cards for the UK, authors from Herbert Smith Freehills Kramer predict
The UK’s Labour government has an unpopular prime minister, an unpopular chancellor and not a lot of good options as it prepares to deliver its autumn Budget
Awards
The firms picked up five major awards between them at a gala ceremony held at New York’s prestigious Metropolitan Club
The streaming company’s operating income was $400m below expectations following the dispute; in other news, the OECD has released updates for 25 TP country profiles
Software company Oracle has won the right to have its A$250m dispute with the ATO stayed, paving the way for a mutual agreement procedure
If the US doesn't participate in pillar two then global consensus on the project can’t be a reality, tax academic René Matteotti also suggests
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