Issues

On June 21 2018, the Australian Taxation Office (ATO) released updated guidelines on the corporate residency test in Taxation Ruling TR 2018/5 and Draft Practical Compliance Guidelines PCG 2018/D3.

Tax Reform Law 20.780 of 2014 introduced Article 41, letter H to the Chilean Income Tax Law, setting new criteria in order to determine whether a preferential tax regime was characterised for Chilean tax matters.

During a debate at the European Parliament in mid-April 2018, a representative from the Council of the European Union confirmed to members of the European Parliament (MEPs) that there were "unresolved political issues" which prevented agreement at the council on the European Commission's April 2016 pending proposal for public country-by-country reporting (public CbCR). The two largest parties in the European Parliament, the EPP (Christian Democrats) and the S&D (Social Democrats), asked the council to unblock the negotiations on the proposal for public CbCR. This was generally understood to be the last chance to reach a deal as Austria, which holds the six-monthly rotating EU Council presidency from July 1 to December 31 2018, and could drive discussions in the council forward, is not in favour of the commission's proposal. Germany's new Federal Finance Minister Olaf Scholz said in June 2018 that the German government needed more time and he also counselled caution about the Commission's proposal and hinted at following a tax-centric approach instead.