Proposed changes to the Income Tax Act, contained in the 2019 draft Taxation Laws Amendment Bill, were released for comment by the National Treasury on July 21 2019.

Multinationals across all sectors should be ready as fundamental changes to the international taxation system make their way into reality. Alison Lobb, Robert Stack and Paul Riley introduce this special report.

The OECD’s work around the digitalisation of the economy is proceeding at a rapid pace and many multinational enterprises may be surprised at the scope of changes to the international tax framework. These changes could impact all larger multinationals, not just those that consider themselves part of the digital economy.

Alex Lebsanft and Sarah Gard of DLA Piper Australia analyse a recent Full Federal Court decision on the Australian Taxation Office’s application of the country’s anti-avoidance rules to treat capital returns as dividends

S Vasudevan, Prachi Bhardwaj, and Prakhar Pandey of Lakshmikumaran & Sridharan question the interpretational clarity of the rules and highlight the practical challenges in limiting interest paid to associated enterprises

Indian writ courts are increasingly scrutinising the mechanical invocation of extended limitation under goods and services tax, say Sahana Rajkumar, Derlene Joshna, and R Amrith of Lakshmikumaran and Sridharan Attorneys

The ruling clarifies that Spain cannot restrict VAT exemptions for general services directly necessary to independent groups’ exempt activities, says Fernando Matesanz of Spanish VAT Services

Nils Schmid and Isabelle Berking of KPMG Sweden analyse the possibilities for sovereign wealth funds to claim refunds of Swedish withholding tax following a recent proposal referred to the Council on Legislation

Jian-Cheng Ku and Taco Pennings of DLA Piper Netherlands discuss a recent ruling by the Dutch Supreme Court regarding the calculation of corporate income tax interest

Gabriel Caldiron Rezende of Machado Associados comments on the latest developments related to the beginning of the Brazilian consumption tax reform test phase and considers the next steps

Rodrigo Winter Salgado of PwC Chile outlines the country's proposed foreign investment regime, comparing it with past frameworks and highlighting potential tax and legal protections for local and international investors

Sandra Benedetto and Nicolás Foppiano of PwC Chile explain the country’s new VAT rules for international purchases, eliminating the $41 exemption and requiring foreign platforms to collect VAT on cross-border sales

Chris Hall of Vertex explains how e-invoicing is becoming essential for multinational businesses, enabling compliance, operational efficiency, and friction-free participation in global trade amid increasingly digital tax regimes

Bernardo Mesquita of Morais Leitão, Galvão Teles, Soares da Silva & Associados examines how AI can enhance tax administration efficiency while raising significant transparency, accountability, and taxpayer-rights concerns that governments must address

Dinko Dinev of Deloitte Luxembourg explores how automation is transforming debt pricing studies in transfer pricing, highlighting efficiency gains but also analytical risks that can arise if technology is misapplied