June 2018

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Asia Tax Awards 2018

World Cup? England have as much chance of winning that as the Asia Tax Awards!

Global interest limitation rule: A matter of time?

How the ATAD is pushing Austrian business to restructure

MNEs hit by Australia’s R&D tax measures in 2018 budget

Coca-Cola optimistic ahead of IRS dispute ruling

ATO prepares for Australia’s low-value goods GST change

The irresistible rise of Andersen Tax

Digital tax dominates at the Asia Tax Forum 2018

Special features - June 2018

Argentina: Regulations on certain tax reform aspects

Canada: Selected international tax measures from the 2018 Canadian budget

Chilean IRS interpretation of Article 12 of Chilean double tax treaties

New Chinese tax incentives for innovation and private pension provision

Germany: Post-BEPS challenges and transfer pricing solution requirements in central management functions

Hong Kong introduces an enhanced R&D tax incentive

India: Supreme Court rules on the tax implications of loan waivers

Ireland: High Court to hear case on deductibility of foreign withholding tax

Transfer pricing framework in Italy: formal alignment to the OECD principles

New opportunities for business cooperation between Luxembourg and Ukraine

Malta: Malta Budget Measures Implementation Act 2018

New Zealand: Tax credit for research and development from April 2019

New commercial property tax in Poland

Does an asset deal prevent the transfer of historical tax risks in Russia?

South Africa: How the MLI will impact on investment structures involving Mauritius

Spain: Participation exemption for real estate rental entities

Switzerland: ALPS: International social security compliance in Switzerland has just gone digital

Turkey introduces another tax amnesty

US Inbound: Sale of partnership interest

IRS issues APA statistics for 2017

Tax Relief

Europe Women in Business Law Awards: 2018 winners

International updates - June 2018

International Correspondents

Features

New Analysis

Tax Relief

Special Features

Editorial

Sponsored

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Sponsored by Fenwick & West

US Inbound: Sale of partnership interest

The 2017 Tax Act added new Section 864(c)(8) on the sale of a partnership interest. The provisions introduce rules that were disputed in Grecian Magnesite v Commissioner.

David Forst, May 29 2018
Sponsored by Matheson

Ireland: High Court to hear case on deductibility of foreign withholding tax

The Irish Revenue Commissioners (Revenue) were successful in arguing before the Appeal Commissioners that no general trading deduction should be available for excess foreign tax incurred on royalties where an Irish tax credit was claimed for part of the foreign tax withheld. The decision is being appealed to the High Court.

Brian Doohan, May 29 2018

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