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

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Direct Tax

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A taxing week: Ryan’s day at the zoo was more than animalistic self-promotion

CSR initiatives can sometimes venture into virtue signalling, but Ryan’s tax literacy event for schoolchildren was a genuine and necessary endeavour

Tom Baker, May 01 2026

Direct Tax

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This week in tax: Grant Thornton extends consolidation drive to Australia

Grant Thornton advanced plans to integrate its Australian firm into its US arm, as tax developments spanned law firm hires, aviation levies and digital services taxes

Tom Baker, May 01 2026

Transfer Pricing

Africa

TP audits are moving upstream, but can African authorities keep pace?

A new focus on early intervention and increased AI use is transforming how tax authorities are approaching TP audits, though capacity-constrained jurisdictions risk falling behind

Akashni Ashok Latchanna, April 30 2026

Direct Tax

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French tax authority leads way in AI adoption

The French administration has used AI to detect undeclared swimming pools and verandas but always includes a human in the loop, the AI in Tax Forum heard

Ed Conlon, April 29 2026

Direct Tax

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HMRC invites taxpayers to stress-test pillar two filings in ‘private beta’

The UK tax authority’s deputy director of large business also reassured taxpayers that HMRC will not ‘nitpick’ returns

Tom Baker, April 28 2026

Direct Tax

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Pillar two a ‘box-ticking’ exercise, admits MNE tax head

Sucafina’s tax chief was speaking at the ITR Pillar 2 Forum in London alongside experts from HMRC and other organisations

Ed Conlon, April 28 2026

Direct Tax

India Supreme Court

Tiger Global ruling in India: scope, limits and risks

India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist

Ravish Bhatt, April 28 2026

Direct Tax

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Unity Advisory appoints AI chief as firm hits 100 employees

The UK-based big four spin-off firm has hired Marc Lien, who declared that most AI in professional services today is ‘cosmetic’

Sam Sholli, April 27 2026

Direct Tax

Pillar two is revising global tax competition with a 15% minimum tax rate

A taxing week: Brazil’s pillar two carve-out request prolongs a death by a thousand cuts

Projected revenue losses and exemption requests are harming the project’s capability and viability

Sam Sholli, April 24 2026

Indirect Tax

Prison

This week in tax: HMRC jails payroll fraudsters for 22 years

HMRC secured lengthy prison sentences in a major payroll VAT fraud case, while law firms announced tax promotions and hires

Tom Baker, April 24 2026