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

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Pillar two has eroded but not imploded: tax academic

Pillar two may be raising less than expected, but professor René Matteotti says the regime is still changing multinational tax behaviour

Sam Sholli, July 30 2026

Transfer Pricing

Brazil customs shipping

Brazil’s new customs valuation tools: TP documentation becomes harder to ignore

Multinationals importing goods into Brazil may need to align TP files and customs documentation more closely as authorities gain new tools to challenge related-party transactions

William Roberto Crestani, July 30 2026

Direct Tax

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Grant Thornton sets eyes on big four with $5bn CBIZ acquisition

The private equity-backed deal hands Grant Thornton immediate and impressive US scale, but World Tax data suggests the firm still has work to do to gain recognition

Sam Sholli, July 29 2026

Direct Tax

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Talking to Josh Thomas, the entrepreneur's adviser with 128,000 followers

From Instagram content to £100m transactions, the founder of Thomas & Co International discusses building a modern tax and accounting firm for business founders

Tom Baker, July 29 2026

Direct Tax

GAAR in India: substance, purpose, and the limits of legitimate tax planning

Growing GAAR scrutiny is driving taxpayers to look beyond legal form and demonstrate the commercial rationale underpinning tax-efficient structures

Sanjay Sanghvi, July 28 2026

Direct Tax

Beyond the Headlines: How MHA plans to scale up after revenues soar

Pillar two has been clients’ ‘biggest headache’ but also a driver of growth for MHA, which believes it has the edge over its big four rivals

Sam Sholli, July 27 2026

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

TP document - compliance.jpg

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

KPMG australia podcast article header

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