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 technology, media and telecommunications (TMT) sector may be directly affected by the G20/OECD digital economy tax proposals. Sajeev Sidher and Kaidi Liu of Deloitte Tax LLP look at the uncertainties ahead.

Bharathi Krishnaprasad of Lakshmikumaran & Sridharan analyses an Indian Supreme Court decision that expands the concept of permanent establishment and raises fresh questions about taxable presence without physical operations

Benjamin P Simatupang and Welly Armantha Napitupulu of GNV Consulting review Indonesia’s latest tax updates, including new income tax rules for e-commerce, changes to crypto asset taxation, gold bar levies, and revised import policies

Jun Au and Eddie Ahn of DLA Piper Australia examine the High Court’s 4-3 ruling in favour of PepsiCo, clarifying when royalty withholding tax and the diverted profits tax apply to distribution arrangements in Australia

Razvan Ungureanu and Teona Braia of EY Romania explain the initiative’s benefits, challenges, and implications for large companies operating across multiple jurisdictions in Europe

João Sousa Magalhães of Morais Leitão, Galvão Teles, Soares da Silva & Associados considers the impact of the Portuguese tax authorities’ rulings on early redemptions and lump-sum payments from foreign pension plans

Paolo Ludovici, Andrea Iannaccone, and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici assess whether Italy’s reforms meet European Court of Human Rights standards on safeguards for inspections of homes and business premises

Paulo Victor Vieira da Rocha and Marina Fernandes of VRMA Advogados analyse the Brazilian Federal Supreme Court’s review of the constitutional boundaries of the CIDE levy on international payments

Renata Colafêmina and Rafaela Calçada Cruz of Machado Associados examine full non-cumulative taxation under Brazil’s new IBS/CBS regime, the current consumption system’s credits restrictions, and the challenges of the new tax model

The protocol amending the Brazil–China double tax treaty is aimed at improving legal certainty, reducing withholding taxes, and preventing treaty abuse, say Paulo Victor Vieira da Rocha and Murilo Jakuk of VRMA Advogados

Henriette Fuchs of Yaron-Eldar, Paller, Schwartz & Co in Tel Aviv reports on two substantial new tax benefits designed to stimulate and preserve continued investment in technology companies

Henriette Fuchs of Yaron-Eldar, Paller, Schwartz & Co in Tel Aviv concludes the follow-up article on SAFE investments in Israel, outlining the relative certainty of walking the safe “green path”.

In the first of a two-part article, Henriette Fuchs of Yaron-Eldar, Paller, Schwartz & Co in Tel Aviv reports on Israel tax authorities’ acceptance of the SAFE for investment in innovative and tech companies.

Michael Bernard of Vertex says adapting to the US’s challenging tax regime relies on an understanding of what is known as the nexus principle

With 45 states imposing a sales tax, Michael Bernard of Vertex explains the key points to note for European businesses aiming to broaden their market and capitalise on the e-commerce boom in the US

Mark Martin and Thomas Bettge of KPMG in the US discuss the recent amount B consensus document and the associated compliance challenges

Niklas Elofsson and Vsevolod Konyshev of KPMG Sweden explore how tax functions can unlock demonstrable efficiency gains by using generative AI tools in a budget-constrained transformation landscape

Johannes Bangum, Maria Barenfeld, and Peter Nilsson of KPMG Sweden explain the main pillar two issues that arise in corporate acquisitions, including scope acceleration, top-up tax responsibilities, and earnout treatment

Paolo Ludovici and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici discuss the latest developments in the OECD International Compliance Assurance Programme and evaluate its role within the framework of tax certainty