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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Indirect Tax

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Direct Tax

Implementing the OECD side-by-side package: what MNEs must do now

MNEs now face a shift from modelling to execution as the side‑by‑side deal forces tax teams to upgrade systems, harmonise data, and prevent costly pillar two mismatches

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Direct Tax

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A taxing week: Big four should clarify their AI strategies, or risk further talent losses

As recent surveys suggest a disconnect between AI adoption and employee engagement, the big four risk digging themselves into a strategic hole

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This week in tax: Survey shows widespread use of AI in tax, but strategy lacking

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Sam Sholli, March 27 2026

Transfer Pricing

AI will power HMRC’s continued quest for TP revenue, advisers suggest

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Direct Tax

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Tom Baker, March 26 2026

Indirect Tax

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Brazil’s tax reform: how the IBS impacts municipalities

Brazil’s shift to a nationwide consumption tax is more than conceptual; it fundamentally transforms municipal revenue, enforcement, and administrative disputes

Wesley Fragas, March 25 2026

Indirect Tax

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‘Welcome clarification’: experts dissect CJEU loyalty programme VAT ruling

While some advisers praised the ruling’s definition of a ‘voucher’ for VAT purposes, a UK partner said the case left unanswered questions

Sam Sholli, March 25 2026

Direct Tax

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Brazilian MNEs struggling to align pillar two with domestic tax incentives

While pillar two has been enacted on paper in Brazil, companies are encountering a range of practical compliance issues, ITR has heard

Sam Sholli, March 24 2026