International updates - July/August 2016

July 19 2016

The latest international updates from our correspondents around the world.

Argentina: Tax amnesty and developments sent to Congress

Brazil: Computer software included in the concept of copyrights for the purposes of the double tax convention between Brazil and Finland

Canada: Important Deadline Approaching under Canada’s “upstream loan” Rules

Chile: Entry into force regime for Chile’s General Anti-Avoidance Rule

Chile: Understanding the new employee stock option plans

Cyprus: Cyprus immovable property tax reform

Germany: Draft tax law includes BEPS measures including CbCR requirements

Greece: Treaty analysis: Greece-Cyprus DTT tax credit mechanism relating to dividend payments

India: Renegotiation of tax treaties by India

Indonesia: New tax amnesty law and real estate investment funds in Indonesia

Ireland: Guidance published on secondary reporting mechanism for CbC reporting

Italy: Advance ruling for new investments in light of the recent clarifications provided by tax authorities

Luxembourg: Crowdfunding in the EU: VAT consequences

New Zealand: Changes coming for employee share schemes

Norway: Foreign shareholders face 10-year withholding tax reassessments after Supreme Court ruling

Poland: GAAR comes into force in Poland

Russia: Companies must comply with new waste rules or face environmental tax

Serbia: Serbia clarifies registration of foreign entities for VAT purposes

South Korea: Recent ruling clarifies whether foreign limited partnership can be looked through for purposes of treaty application

Spain: Participation exemption in ‘pure holding companies’

Switzerland: Swiss parliament approves Corporate Tax Reform III

US Inbound: Medtronic wins US transfer pricing case

Topics

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Tom McDanell on tackling growth with patience

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This week in tax: Judge denies ex-US Supreme Court advocate retrial bid

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Exclusive: Andersen Global bolsters India presence through JMP Advisors agreement

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HMRC’s GfC13: why governance is paramount for taxpayers and advisers

HMRC’s growing focus on evidencing tax decisions is shifting attention from technical accuracy to governance, requiring businesses to demonstrate how positions were reached and documented

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Direct Tax

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KPMG Australia hit with ban on new contracts amid scandal

Australia’s Department of Finance will also commission an independent review of KPMG’s governance, culture, ethics and integrity frameworks, it has revealed

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Capital v revenue in R&D – isolated concerns or a future battleground? Part two

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