The arrival of a team from Brazilian rival Costa Tavares Paes Advogados brings SiqueiraCastro’s tax headcount to seven partners and 30 associates
CSR initiatives can sometimes venture into virtue signalling, but Ryan’s tax literacy event for schoolchildren was a genuine and necessary endeavour
Grant Thornton advanced plans to integrate its Australian firm into its US arm, as tax developments spanned law firm hires, aviation levies and digital services taxes
A new focus on early intervention and increased AI use is transforming how tax authorities are approaching TP audits, though capacity-constrained jurisdictions risk falling behind
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Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe examine a recent decision concerning the transfer pricing treatment of non-remunerated intra-group guarantees, focusing on economic substance, legal form, and group-level business justifications -
Sponsored by McCarthy TétraultThe key changes under Budget 2025 and the outlook for 2026 raise several areas of heightened focus for taxpayers, say Matthew Kraemer, Adam N Unick, and Justin Ng of McCarthy Tétrault
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Sponsored by Lakshmikumaran & SridharanThe Tiger Global Supreme Court ruling weakens the status of tax residency certificates under tax treaties and increases substance‑based scrutiny, say S Vasudevan, Bharathi Krishnaprasad, and Krishna Laasya V of Lakshmikumaran & Sridharan
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For the past couple of years, many commentators have used the term “disruption,” sometimes without much forethought, writes Carolyn Bailey, Americas digital tax administration services leader at EY. It sells newspapers, magazines and journals, and it attracts television viewers.
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Overall, 2017 saw significant changes in Chinese tax rules and in the broader regulatory environment. Many of the changes reflected the reorientation of government policy towards an evolving cross-border investment landscape. The digitisation of the economy, as well as the tax administration, was also a key driver of developments.
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Generally, a gain realised by a non-resident of Canada on the sale of shares of a corporation that derive more than 50% of their value from Canadian real property (CRP), being real properties or resource properties situated in Canada, at any time in the 60 months preceding the sale is subject to tax in Canada. Such shares are known as "taxable Canadian property" (TCP). Exceptions exist for holdings of shares listed on a designated stock exchange where the holder owns less than 25% of any class of shares of the issuer and under the provisions of certain tax treaties. On May 1 2017, the Canada Revenue Agency (CRA) released a Technical Interpretation (TI) (2015-0624511I7) describing the approach that should be followed to make the 50% determination if the property of the corporation (Parentco) includes shares or debt of a wholly-owned subsidiary corporation (Subco). Although the TI addresses a prior version of the TCP definition, the comments appear to be applicable to the current definition, which employs essentially identical language relating to derivation of value.
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The concept of corporate legal migration, i.e. the change of domicile of any legal entity, is not included in the Chilean tax law. Thus, its effects depend on the concept of legal residency given by the country from which the company migrates, as well as by the country to which the company moves to.
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On June 27 2017, the Prime Minister of Bosnia and Herzegovina adopted a decision ratifying the income tax treaty between Bosnia and Herzegovina and Romania, which was signed on December 6 2016. When it becomes effective (pending Romania's ratification), the treaty will replace the former Yugoslavia–Romania income and capital tax treaty of 1986.
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Read this month's special features on Tax technology and transformation and Mexico
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India's Supreme Court has reinforced its decision in the Formula One permanent establishment (PE) case and further clarified the application of service and agency PE rules in a recent case.
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As part of the commitment to modernise the tax system, but also with aim of monitoring the fiscal deficit, the Executive Branch presented its proposal for a comprehensive tax reform that it will submit to Congress with the aim of making it applicable from fiscal year 2018 onwards.
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Every year the European Commission adopts its work programme setting out the list of actions it will take in the year ahead. The work programme informs the public and the EU's co-legislators (Council of the EU and European Parliament) of the Commission's political commitments to present new initiatives, withdraw pending proposals and review existing EU legislation.
