December 2015 / January 2016

Main

Implementation, implementation, implementation

The Cunningham column: China gets ready to lead tax world in 2016

The Brockman brief: BEPS implementation: A holiday wish

Deals of the month

GST to be enforced on e-commerce in New Zealand

India to accelerate corporate tax cut

EC grills 11 multinationals on tax; extends tax rulings investigation

2016 Look-Ahead: BEPS implementation to dominate international tax landscape

BEPS Special

Foreword

Inside observations on the BEPS Project

Action 1: Addressing the tax challenges of the digital economy

Action 2: Neutralising the effect of hybrid mismatch arrangements

Action 3: Designing effective controlled foreign company rules

Action 4: Limiting base erosion involving interest deductions and other financial payments

Action 5: Countering harmful tax practices more effectively, taking into account transparency and substance

Action 6: Preventing the granting of treaty benefits in inappropriate circumstances

Action 7: Preventing the artificial avoidance of permanent establishment status

Actions 8-10: Aligning transfer pricing outcomes with value creation

Action 11: Measuring and monitoring BEPS

Action 12: Mandatory disclosure rules

Action 13: Transfer pricing documentation and country-by-country reporting

Action 14: Making dispute resolution mechanisms more effective

Action 15: Developing a multilateral instrument to modify bilateral tax treaties

Intercompany charges below EBIT: A double-edged sword

Special features - December 2015 / January 2016

India’s TP regime takes steps towards global best practices

Albania: Treaty analysis: Albania and Kosovo sign new double taxation agreement

Argentina: Argentina and Mexico sign double tax treaty

Australia: Tax reform topics continue to dominate political scene in Australia

Brazil: Update on the obligation to disclose certain transactions in Brazil

Bulgaria: Treaty analysis: Bulgaria and UK sign new double taxation agreement

Canada: Canadian Federal Court pulls the reins in (slightly) on foreign information requests

Chile: Applicability of the beneficial owner concept for dividends in Chile

Chile: Chilean IRS’s Anti-avoidance Bureau and the Administrative Consultation Procedure

Cyprus: Post-sanctions Iran: Exploring the Iranian market via Cyprus

EU: European Commission issues final decisions in Starbucks and Fiat state aid cases

Germany: Exemption to Germany’s change-in-ownership rules expanded

India: India continues to promote domestic business environment

Indonesia: Indonesia issues a draft Bill for national tax amnesty; plans to cut taxes

Ireland: Ireland confirms AT1 instruments treated as debt

Italy: Companies migrating to Italy: New ‘internationalisation’ decree introduces rules to determine assets and liabilities’ tax basis

FYR Macedonia: Treaty analysis: FYR Macedonia ratifies double taxation agreement with Vietnam

Malta: Malta concludes treaty with Curaçao

Middle East: New incentives for foreign corporations in Kuwait

Montenegro: New VAT exemption incentives in Montenegro

New Zealand: New Zealand introduces Bill to impose GST on cross-border services

Poland: VATable and non-VATable transactions in Poland – allocation of input VAT

Russia: Russian conduit companies – do your sub-holding companies have substance?

Serbia: Treaty analysis: Serbia and Norway double taxation agreement

Spain: Spain opens door to impose penalties on contrived acts or transactions

Switzerland: Switzerland is likely to remain a premier group financing location post-BEPS

Ukraine: Ukraine amends list of low-tax jurisdictions

US Inbound: US issues new guidance on allocation of income

Tax Relief

International Correspondents

Features

New Analysis

Tax Relief

Special Features

Editorial

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India: India continues to promote domestic business environment

In its push towards positioning India as an attractive investment destination and to improve the ease of doing business in the country, the Government has announced further tax initiatives.

Hariharan Gangadharan, December 15 2015

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