International updates - July/August 2015

July 14 2015

The latest international updates from our correspondents around the world.

Argentina: New Argentina-Chile tax treaty creates fresh structuring opportunities

Australia: Australian Budget measures receive royal assent

Bulgaria: The alternative choice for tax planning

Canada: CRA GAAR committee documents compelled – Superior Plus Corp v the Queen

Chile: Transitory regime for goods and income located or perceived abroad

Chile: New instructions regarding provisional withholding on capital gains

China: Implementation guidance issued for Announcement 7 indirect transfers

EU: ‘Tax Transparency Package 2.0’: New EU action plan for fundamental reforms of business taxation in the EU

Germany: Federal Tax Court rules CFC income is not subject to trade tax

Hong Kong: Hong Kong moves towards a favourable Treasury regime

Luxembourg: Luxembourg starts ratification process of four new tax treaties and six amending protocols

Malta: Aviation transactions benefit from Malta tax regime

Middle East: The impact of FATCA on financial institutions in the GCC

Montenegro: New incentive related to cinematography law in Montenegro

New Zealand: Government announces measures for taxing gains from sales of residential property

New Zealand: New director requirements and disclosure obligations for New Zealand companies

Poland: Changes to the Polish VAT law

Russia: New Russian transfer pricing rules for corresponding adjustments

Spain: Spain set to introduce modifications to transfer pricing reporting requirements

Switzerland: Revised draft legislation on Corporate Tax Reform III introduced into parliament

US Outbound: Final anti-inversion regulations retain bright-line substantial business activities test

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A taxing week: HMRC's audit woes will rightly fuel tax adviser concerns

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Wolters Kluwer acquires tax automation provider for €112m

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Peru

TP in Peru: where global profitability policies meet a transaction-by-transaction regime

Peru’s approach to TP is increasingly at odds with OECD-style profitability policies, exposing multinational groups to asymmetric tax adjustments

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Gulf Cooperation Council GCC

How ESR and pillar two are converging across the GCC

Hany Elnaggar examines how the region's legacy economic substance regimes and the OECD's pillar two framework are converging on the same underlying test

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AI tech

Alphatax broadens TP portfolio with double acquisition

The deals for TP Accurate and Intra Pricing Solutions will enhance Alphatax’s ability to support clients with the full TP lifecycle, the tax tech provider claimed

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From advisory to advocacy: why Gunjan Prabhakaran chose litigation

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