International updates - September 2017

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International updates - September 2017

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The latest international updates from our correspondents around the world.

Albania: Law on remission of unpaid tax and custom duties approved

Argentina: Protocol drastically changes tax treaty with Brazil

Australia: Recent developments

Brazil: Obligation to file CbC report when there is no effective competent authority agreement in place for its automatic exchange clarified; Double tax treaty with Russia now in force

Canada: Conservative approach taken to BEPS Multilateral Instrument

Chile: Life insurances with savings are subject to taxation

China: New rules promote foreign investment while tightening regulatory enforcement

Croatia: Advance pricing agreements implemented

Cyprus: Long-awaited transfer pricing guidelines on intra-group financing released

Egypt: VAT increased to 14%

Georgia: Kyrgyzstan ratifies double tax treaty with Georgia

Germany: German anti-treaty shopping rules under scrutiny

Greece: Clarifications on the tax treatment of foreign trusts and foundations

Hong Kong: Courts rule on taxability of property investments

India: Bombay High Court upholds availability of benefits under the India-Mauritius tax treaty

Indonesia: New CFC rule and new anti treaty abuse rule

Ireland: Briefing paper gives insight into Ireland’s international tax policy

Italy: Moving towards the fourth industrial revolution

Luxembourg: New BEPS-compliant IP regime to open up opportunities

Malta: Updates to the CRS guidelines

Mexico: Substance-only tax litigation proceedings introduced

Montenegro: Montenegro and US sign intergovernmental agreement to implement FATCA

New Zealand: MLI positions

Poland: Proposals will not allow investment cost deductions from operational revenue

Portugal: New VAT payment regime on import of goods

Portugal: Ruling on toll manufacturing and distribution activities and permanent establishment

Russia: The latest trends in the beneficial ownership concept

South Africa: Proposed international tax amendments

Spain: Should medics be taxed on invitations to medical seminars?

Switzerland: Swiss VAT consequences for distance selling businesses as of 2019

Turkey: A new audit mechanism: Call for justification

US Inbound: Tax court rules against IRS on tax treatment of disposition of partnership interest

US Outbound: Cancellation of APAs by IRS, abuse of discretion

more across site & shared bottom lb ros

More from across our site

The Australian Taxation Office believes the Swedish furniture company has used TP to evade paying tax it owes
Supermarket chain Morrisons is facing a £17 million ($23 million) tax bill; in other news, Donald Trump has cut proposed tariffs
The controversial deal will allow US-parented groups to be carved out from key aspects of pillar two
Awards
ITR invites tax firms, in-house teams, and tax professionals to make submissions for the 2027 World Tax rankings and the 2026 ITR Tax Awards globally
Pillar two was ‘weakened’ when it altered from a multinational convention agreement to simply national domestic law, Federico Bertocchi also argued
Imposing the tax on virtual assets is a measure that appears to have no legal, economic or statistical basis, one expert told ITR
The EU has seemingly capitulated to the US’s ‘side-by-side’ demands. This may be a win for the US, but the uncertainty has only just begun for pillar two
The £7.4m buyout marks MHA’s latest acquisition since listing on the London Stock Exchange earlier this year
ITR’s most prolific stories of the year charted public pillar two spats, the continued fallout from the PwC Australia tax leaks scandal, and a headline tax fraud trial
The climbdowns pave the way for a side-by-side deal to be concluded this week, as per the US Treasury secretary’s expectation; in other news, Taft added a 10-partner tax team
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