International updates - November 2017

November 05 2017

International Updates

The latest international updates from our correspondents around the world.

Australia: Stapled structures

Brazil: Changes to the oil and gas tax framework; guidance on capital gains; TIEA between Brazil and Switzerland approved

Bulgaria: Bulgaria implements CbCR

Canada: Finance Canada releases proposed investment limited partnership rules

China: Modernised industry regulation, greater oversight, and a strengthened DTA network

Croatia: Croatian local taxes: what’s new in 2017?

Cyprus: Introducing the new VAT appeal procedure

European Union: Public CbCR impasse in EU’s Council and possible impact of President Tusk’s EU reform plans

Germany: Possible tightening of RETT provisions

Greece: GAAR rising: First administrative rulings in the spotlight

India: Draft notification on CbC reporting guidance released

Indonesia: Taxation on e-commerce transactions

Ireland: Budget 2018 maps route for tax modernisation

Italy: First round of CbCR implementation takes place

Malta: Budget 2018

Mexico: The “business reason” in the Mexican tax law

Montenegro: Montenegro hikes VAT rate and amends excise duties

New Zealand: New Zealand to restate and reform trust law

Poland: Debt push down no longer tax deductible from 2018

Portugal: Portuguese budget bill for 2018 brings few tax changes

South Africa: Constitutional validity of retrospective legislation

Spain: Tax implications of ‘malus’ and ‘clawback’ clauses in variable compensation schemes

Switzerland: VAT rate reductions effective from 2018

Turkey: New taxes on the table

US Inbound: US permanent establishment issue

Topics

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more across site & shared bottom lb ros

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Direct Tax

Aerial view of Christ and Botafogo Bay from high angle.

Brazilian MNEs struggling to align pillar two with domestic tax incentives

While pillar two has been enacted on paper in Brazil, companies are encountering a range of practical compliance issues, ITR has heard

Sam Sholli, March 24 2026

Direct Tax

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Guinevere Moore on balancing tax litigation with childcare and ‘paying it forward’

Moore, founding partner of the Chicago tax boutique which bears her name, shares her career wisdom for ITR’s new Women in Tax interview series

March 24 2026

Direct Tax

Baker McKenzie

Clients considering US relocation following pillar two carve-out deal: Baker McKenzie

But partners at the firm admit that jumping ship to the US would not be as easy as some believe

Tom Baker, March 23 2026

Direct Tax

Artificial intelligence

A taxing week: AI is reshaping capital flows and toppling the old tax order

Governments are rewriting tax policy for the AI era, deploying digital taxes, tailored incentives and algorithmic enforcement that redefine where value is created

Teresa Owusu-Adjei, March 20 2026

Direct Tax

This week in tax: KPMG announces Gary Wingrove as new global chairman and CEO

Wingrove will succeed Bill Thomas, who has served in the role since 2017; in other news, Andersen unveiled a sharp increase in revenues for 2025

Sam Sholli, March 20 2026

Transfer Pricing

‘Clear limitations’: Italian advisers differ on intra-group financing TP ruling

Partners are divided on Italy vs PDM D’s analytical depth, evidentiary standards, and what the judgment signals for future intra-group financing cases

Sam Sholli, March 19 2026

Direct Tax

Back office

Back office to backbone: tax risks of evolving global capability centres

As GCCs increasingly become strategic hubs, multinationals face heightened risks around permanent establishment and place of effective management

Mehul Jain, March 19 2026

Direct Tax

wopke hoekstra.jpg

‘Kept the family together’: EU tax chief praises US/OECD pillar two deal

While all options presented ‘drawbacks’, European Commission tax leader Wopke Hoekstra said the controversial US carve-out deal has ‘many benefits’

Sam Sholli, March 18 2026

Direct Tax

FAQs

The pillar two side-by-side agreement: key questions answered

From tech preparations to competitiveness concerns, Tax Systems’ Russell Gammon addresses the most pressing client considerations arising from the SbS deal

Russell Gammon, March 17 2026

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