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

High court 2000.jpg

Dan Neidle defeats £8m libel claim brought by ‘tax avoidance promoter’

The High Court’s dismissal of barrister Setu Kamal’s legal challenge represents the first successful strike-out under a new law on SLAPPs

Sam Sholli, March 11 2026

Indirect Tax

US tariffs

Opinion: Tariff turbulence is a wake-up call for IP attorneys

IP lawyers, who say they are encouraging clients to build up ‘tariff resilience’, should treat the risks posed by recent orders as a core consideration in cross-border licensing

Sanjana Mishra, March 11 2026

Transfer Pricing

Coca-cola

Is Coca-Cola’s ‘Black Swan’ event in sight?

As Coca-Cola awaits a crucial 11th Circuit Court of Appeals decision this year, its multibillion-dollar tax dispute could have profound implications for investors, cash flow, and corporate transparency

Alex Martin, March 10 2026

Direct Tax

Gender equality

Gender equality has improved ‘significantly’: 79% of female tax advisers

However, women in tax face greater career obstacles than their male counterparts, an exclusive ITR survey of more than 100 women tax leaders revealed

Tom Baker, March 09 2026

Direct Tax

jeff soar resized.jpg

Former EY tax leader spearheads WTS UK launch

Under Jeff Soar’s leadership, WTS UK aims to scale to 100 partners within five years and challenge the big four

Tom Baker, March 09 2026

Direct Tax

A taxing week: Deloitte’s culture is about to face a tough test

As the firm embarks on a major shakeup of its EMEA partnerships, some staff will be watching nervously

Ed Conlon, March 06 2026

Direct Tax

Close up shake hands, Considering buying a home, investing in real estate. Broker signs a sales agreement. agent, lease agreement, successful deal.

This week in tax: Ryan acquires property tax consulting firm in US

The buyout of Hucke and Associates continues Ryan’s streak of firm acquisitions; in other news, a UK appeal against VAT on private school fees was dismissed

Sam Sholli, March 06 2026

Direct Tax

Dubai

Iran conflict: UAE tax teams operating as usual despite disruption

Tax teams are responding to usual client demand in the region, albeit with increased working from home flexibility, local sources indicate

Tom Baker, March 05 2026

Indirect Tax

US tariffs

This month in indirect tax: Tariff refund delays may cost US taxpayers $700m per month

A 120-plus-day delay to refunds would cost taxpayers almost $3bn in additional interest, the Cato Institute warned; plus indirect tax updates from February

Sam Sholli, March 04 2026

Direct Tax

UK pound,money of United kingdom close up on white, Pound UK not

US pillar two side-by-side deal will cost UK £700m per year

The Office for Budget Responsibility’s pessimistic pillar two forecast accompanied the UK chancellor’s muted Spring Statement, dubbed ‘as dull as possible’ by one adviser

Tom Baker, March 03 2026