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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Podcasts

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Taxing Times: introducing ITR’s new monthly podcast

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Direct Tax

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While some believe it could have a positive effect on the wider advisory landscape, others argue that HMRC’s ‘red tape’ exercise won’t deter bad actors

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Direct Tax

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

A taxing week: Pillar two will prosper despite US side-by-side arrangement

The political optics of the US’s carve-out deal are poor, but as the Fair Tax Foundation’s Paul Monaghan writes, it preserves pillar two’s guiding ethos

Paul Monaghan, February 27 2026

Direct Tax

This week in tax: PwC commences legal battle with boutique consultancy founded by ex-COO

The big four firm reportedly sent ‘threatening’ correspondence to Unity Advisory over its hiring of ex-PwC partners; plus tax recruitment news from the week

Sam Sholli, February 27 2026

Direct Tax

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Ex-US Supreme Court advocate convicted on 12 counts in tax trial

Tom Goldstein, who was represented by US law firm Munger, Tolles & Olson, denied wilfully cheating on his taxes and blamed errors on his staff

Sam Sholli, February 26 2026

Transfer Pricing

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TP documentation in a fragmented world: how to limit audit triggers

Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions

Daniel Moalusi, February 26 2026

Direct Tax

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‘Tax at breaking point’: Thomson Reuters’ AI tech hits one million users

The profession is fundamentally restructuring itself around what tax and accounting work should be, a Thomson Reuters leader told ITR

Sam Sholli, February 24 2026

Direct Tax

Deloitte unveils €20bn EMEA combination

The big four firm is consolidating 16 entities across the region to create a single 6,000-partner behemoth

Tom Baker, February 24 2026

Indirect Tax

The IBS and why it changes everything in Brazil’s consumption tax system

Brazil’s tax reform unifies consumption taxes to simplify rules, centralise administration and reduce legal uncertainty

Wesley Fragas, February 24 2026

Direct Tax

A&M Tax launches dedicated pillar two, TP team in Saudi Arabia

The ever-expansive firm has once again attracted a former ‘big four’ talent to lead the new offering

Tom Baker, February 23 2026