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

Tax transparency reputation

A taxing week: Country-by-country reporting just became everyone’s business

Public country-by-country reporting is exposing multinational tax data to investors, journalists and competitors, creating fresh risks for businesses

Sandy Markwick, July 24 2026

Direct Tax

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How integrated FP&A data powers pillar two compliance

Pillar two compliance is creating unprecedented data demands for multinational tax departments, making closer collaboration with FP&A teams essential for accurate reporting and audit readiness

Chris Porter, July 23 2026

Direct Tax

KordaMentha launches tax disputes practice with ATO, PwC Australia hires

Among the arrivals is Andrew Howell, who leaves scandal-hit PwC Australia after representing PepsiCo in a high-profile TP dispute

Sam Sholli, July 22 2026

Podcasts

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Podcast: What the KPMG Australia scandal means for the big four

ITR's podcast examines whether the big four have overarching cultural issues and assesses the competitive threat of technology-backed transfer pricing firms

Tom Baker, July 22 2026

Direct Tax

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MHA records 12% revenue rise a year on from London IPO

The UK advisory firm has seen its global revenues expand by £27.2m following its listing and acquisition of Baker Tilly South-East Europe

Sam Sholli, July 21 2026

Direct Tax

Michael Ebeid and John Sams, KPMG

KPMG Australia’s new CEO vows to improve culture following scandal

Tax-trained John Sams, previously the firm’s CFO and COO, was appointed after a rigorous process, KPMG said

Tom Baker, July 21 2026

Transfer Pricing

Intellectual property Africa

Pay attention to tax when taking IP across borders in Africa

From Mauritius substance rules to Kenyan SEP tax and South African anti-avoidance measures, businesses must navigate growing scrutiny of cross-border IP structures in Africa

The tax team at Bowmans, July 21 2026

Direct Tax

Global digital

Beyond the headlines: Lessons from pillar two’s first and farcical filing deadline

ITR spoke to multinationals, advisers and software providers about a June 30 deadline defined by faulty portals, high compliance costs and hard lessons

Tom Baker, July 20 2026

Direct Tax

Compliance frustration onerous pillar two

A taxing week: Pillar two revenue shortfall a gut-punch for MNEs

After years of onerous pillar two prep, businesses will be galled in seeing tax revenues outweighed by compliance costs

Tom Baker, July 17 2026

Direct Tax

The EY US dispute: why secondment structures need fresh Indian review

Tax advisers should revisit India secondment arrangements after the EY US ruling strengthened the Centrica precedent and raised fresh withholding concerns

Aditi Goyal, July 16 2026