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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Indirect Tax

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IBS vs. ICMS: why Brazil’s new VAT is a fundamental paradigm shift

While the IBS incorporates taxable events previously covered by state and municipal taxes, its governance and operational logic represent a significant departure from the legacy model

Wesley Fragas, March 31 2026

Direct Tax

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Exclusive: Ryan continues London investment with new UK HQ

The new office on the fourth floor of 4 More London will span 14,230 square feet, with the potential to expand to the first and second floors

Tom Baker, March 30 2026

Direct Tax

Implementing the OECD side-by-side package: what MNEs must do now

MNEs now face a shift from modelling to execution as the side‑by‑side deal forces tax teams to upgrade systems, harmonise data, and prevent costly pillar two mismatches

Jelena Mihić Munjić, March 30 2026

Direct Tax

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A taxing week: Big four should clarify their AI strategies, or risk further talent losses

As recent surveys suggest a disconnect between AI adoption and employee engagement, the big four risk digging themselves into a strategic hole

Sam Sholli, March 27 2026

Direct Tax

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This week in tax: Survey shows widespread use of AI in tax, but strategy lacking

Almost three-quarters of surveyed tax professionals are concerned about inaccurate AI outputs; in other news, Dentons hired a partner from CMS to lead its Belgian tax team

Sam Sholli, March 27 2026

Transfer Pricing

AI will power HMRC’s continued quest for TP revenue, advisers suggest

Long-running, high-value and complex enquiries are a significant reason for HM Revenue and Customs’s increased TP yield, experts suggest

Sam Sholli, March 26 2026

Direct Tax

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Clients laud Indian tax advisers’ technical knowledge amid legislative upheaval

Landmark legal updates in India have led companies to prioritise specialised tax advisers over accountants, ITR has found

Tom Baker, March 26 2026

Indirect Tax

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Brazil’s tax reform: how the IBS impacts municipalities

Brazil’s shift to a nationwide consumption tax is more than conceptual; it fundamentally transforms municipal revenue, enforcement, and administrative disputes

Wesley Fragas, March 25 2026

Indirect Tax

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‘Welcome clarification’: experts dissect CJEU loyalty programme VAT ruling

While some advisers praised the ruling’s definition of a ‘voucher’ for VAT purposes, a UK partner said the case left unanswered questions

Sam Sholli, March 25 2026

Direct Tax

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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