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

Topics

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Direct Tax

HMRC’s GfC13: why governance is paramount for taxpayers and advisers

HMRC’s growing focus on evidencing tax decisions is shifting attention from technical accuracy to governance, requiring businesses to demonstrate how positions were reached and documented

Rebecca Arthur, June 17 2026

Direct Tax

KPMG image.jpg

KPMG Australia hit with ban on new contracts amid scandal

Australia’s Department of Finance will also commission an independent review of KPMG’s governance, culture, ethics and integrity frameworks, it has revealed.

Sam Sholli, June 16 2026

Direct Tax

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Capital v revenue in R&D – isolated concerns or a future battleground? Part two

In the second instalment of this two-part series, Jayne Stokes takes a practical approach to navigating the capital v revenue question for UK R&D claims for software development, and shares pointers for businesses

Jayne Stokes, June 16 2026

Podcasts

Taxing Times May 2026 article header updated

Podcast: Is bigger better? Unpacking Ryan's Svalner Atlas acquisition

ITR's latest podcast considers how transformational the buyout could be in Ryan's quest for global advisory reach and analyses a recent boom in demand for private client advisory services

Tom Baker, June 15 2026

Indirect Tax

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ITR set for Indirect Tax Forum 2026 in Amsterdam

The event comes at an important moment for professionals dealing with practical realities related to this practice area

Sam Sholli, June 12 2026

Direct Tax

A taxing week: the Germans are all at sea over PE

Germany’s dogmatic restriction of third-party investment in tax advisory firms will only serve to slow down innovation and access to justice

Aled Griffiths, June 12 2026

Direct Tax

This week in tax: Watchdog warns Ireland over corporate tax spending

The Irish government has been told that it’s spending too much of its corporation tax receipts and should instead focus on running bigger surpluses; plus, the IRS is set to merge tax practitioner offices

Sam Sholli, June 12 2026

Transfer Pricing

HMRC Making Tax Digital

‘Gamechanger’: ICTS system will be boon for HMRC, says Ryan TP principal

A company risks double taxation, penalties and inquiry cost if it submits a form with anomalies under the new system, Asker Ali also tells ITR

Sam Sholli, June 11 2026

Transfer Pricing

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Transfer pricing automation in ERP systems: traps for compliance

Arindam Mitra and Robin Hart examine how aggregate TP rules clash with transaction-level customs rules, creating compliance risks and requiring granular, SKU-level pricing strategies

Arin Mitra, June 11 2026

Direct Tax

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KPMG gears up for hearing amid confidential leaks scandal

The scandal has come just three years after the PwC tax leaks controversy and has prompted KPMG’s Australian chief executive to resign

Sam Sholli, June 10 2026