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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Direct Tax

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A taxing week: Ryan’s day at the zoo was more than animalistic self-promotion

CSR initiatives can sometimes venture into virtue signalling, but Ryan’s tax literacy event for schoolchildren was a genuine and necessary endeavour

Tom Baker, May 01 2026

Direct Tax

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This week in tax: Grant Thornton extends consolidation drive to Australia

Grant Thornton advanced plans to integrate its Australian firm into its US arm, as tax developments spanned law firm hires, aviation levies and digital services taxes

Tom Baker, May 01 2026

Transfer Pricing

Africa

TP audits are moving upstream, but can African authorities keep pace?

A new focus on early intervention and increased AI use is transforming how tax authorities are approaching TP audits, though capacity-constrained jurisdictions risk falling behind

Akashni Ashok Latchanna, April 30 2026

Direct Tax

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French tax authority leads way in AI adoption

The French administration has used AI to detect undeclared swimming pools and verandas but always includes a human in the loop, the AI in Tax Forum heard

Ed Conlon, April 29 2026

Direct Tax

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HMRC invites taxpayers to stress-test pillar two filings in ‘private beta’

The UK tax authority’s deputy director of large business also reassured taxpayers that HMRC will not ‘nitpick’ returns

Tom Baker, April 28 2026

Direct Tax

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Pillar two a ‘box-ticking’ exercise, admits MNE tax head

Sucafina’s tax chief was speaking at the ITR Pillar 2 Forum in London alongside experts from HMRC and other organisations

Ed Conlon, April 28 2026

Direct Tax

India Supreme Court

Tiger Global ruling in India: scope, limits and risks

India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist

Ravish Bhatt, April 28 2026

Direct Tax

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Unity Advisory appoints AI chief as firm hits 100 employees

The UK-based big four spin-off firm has hired Marc Lien, who declared that most AI in professional services today is ‘cosmetic’

Sam Sholli, April 27 2026

Direct Tax

Pillar two is revising global tax competition with a 15% minimum tax rate

A taxing week: Brazil’s pillar two carve-out request prolongs a death by a thousand cuts

Projected revenue losses and exemption requests are harming the project’s capability and viability

Sam Sholli, April 24 2026

Indirect Tax

Prison

This week in tax: HMRC jails payroll fraudsters for 22 years

HMRC secured lengthy prison sentences in a major payroll VAT fraud case, while law firms announced tax promotions and hires

Tom Baker, April 24 2026