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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Direct Tax

handshake

Charles Russell Speechlys enters US with private client splash

The firm has hired a team of private client lawyers from Withers to launch in New York and Connecticut, though ITR analysis suggests it faces stiff competition

Sam Sholli, July 08 2026

Direct Tax

‘Multiple versions of truth’: EY leader on in-house tax data challenges

The ability of tax authorities to receive and analyse data is becoming ‘quite advanced’, warns Stuart Lang, head of EY’s compliance co-sourcing solution

Sam Sholli, July 08 2026

Direct Tax

Royal Courts of Justice in London

Burlington v HMRC and the interpretation of double taxation treaty anti-avoidance clauses

The Court of Appeal ruling clarifies that treaty benefits are not abusive where transactions are commercially driven, providing greater certainty on “main purpose” anti-avoidance tests

Matthew Greene, July 07 2026

Transfer Pricing

Person working on screen with financial graphs and overlaid network

Beyond the headlines: Are TP software providers challenging tax advisory hegemony?

Despite the Netherlands featuring an unusual concentration of World Tax-ranked technology-led providers, sources believe there’s a long way to go to challenge the established players

Tom Baker, July 06 2026

Direct Tax

A taxing week: EY allegations suggest big four scandal at all levels

Ethics seems to be playing a subservient role to an entitlement culture borne out of a pervasive ‘revenue at all costs’ mentality at the big four

Sam Sholli, July 03 2026

Direct Tax

Hogan Lovells Cadwalader’s $3.6bn merger goes live

Historical World Tax data suggests the ‘largest law firm merger in history’ may not pose a serious threat to the world's leading tax practices

Noemi Distefano, July 02 2026

Direct Tax

Libya

Libyan tax disputes: choosing between settling and challenging

The repeal of Libya’s statute of limitations and tougher enforcement leave taxpayers navigating a high-stakes choice between conciliation and litigation

Salaheddin El Busefi , July 02 2026

Direct Tax

partner promotions

Tax lawyers make up nearly half of Withers’ promotions round

All the tax partners elevated across the UK, US and Singapore were private client specialists, continuing a market trend of intense investment and competition

Tom Baker, July 01 2026

Transfer Pricing

Reptune_CEO_Rolf van de Velde.jpg

Exclusive: Dutch TP software provider Reptune names new CEO

Rolf van de Velde, dubbed ‘an expert chosen by experts’, is tasked with scaling Reptune’s self-service compliance offering

Sam Sholli, June 30 2026

Direct Tax

Merger international

Perkins Coie and Ashurst merger closes to form $2.8bn firm

The newly combined firm brings together more than 3,500 practitioners across 52 offices, with flagship hubs in Seattle, London, Sydney and New York.

Noemi Distefano, June 29 2026