Magazine
February 2017

Magazine Archive

The Brockman brief: Leadership attributes: developing relationships

Tax professionals from all areas of the tax sphere need to move outside their comforts zone to grasp the opportunities available and boost skills. Keith Brockman highlights the need for internal and external networking that could offer previously unknown possibilities.
Deals of the month

See who has done the tax work on this month's biggest deals.
EU to take ‘nuclear option’ on VAT fraud with reverse charge systems
No more secret tax rulings in the EU?
EC delves deeper into Engie’s tax affairs
India’s stalled GST regime
President Trump: A new era of taxation
Malta committed to EU presidency despite tax haven accusations
France urged to make bigger corporate tax cuts
Q&A: China’s changing tax landscape

China’s tax environment is rapidly changing to become more aligned with international standards, alongside more transparent and business-friendly policies. The Director General of International Taxation for China Tizhong Liao talks to Amelia Schwanke about his thoughts on recent tax developments and what businesses can expect in 2017.
Constitutions: Could paying a ‘fair share’ of tax already be enshrined in law?

Politicians and campaigners are fond of saying that companies should pay their ‘fair share’ of tax, but the phrase is over-used and lacks legal meaning and backing, becoming little more than a cliché. However, new research has identified clauses in the Constitutions of 15 countries – including two of the G7 member states – which identify an obligation to contribute to the public purse. Joe Stanley-Smith explores how this could force companies to take more notice of the fair-share debate.
M&A considerations for 2017: Don’t let tax derail the deal

Tax considerations will never make a deal, but they certainly can break a deal. Laurence Field, a senior tax and corporate business partner at national audit, tax and advisory firm Crowe Clark Whitehill, reflects on the M&A tax landscape that evolved through 2016 and looks ahead to assess what businesses need to know if they are planning to get a transaction over the line in 2017.
The post-BEPS advantages of the Netherlands

Roelof Gerritsen and Ivo Kuipers, both partners at Atlas Tax Lawyers in the Netherlands, look at why the country will remain a prime location for multinationals and foreign investors as governments worldwide transition towards more harmonised tax rules in line with the OECD’s BEPS Project.
India’s renegotiated DTAs creating investment diversions

India’s recent renegotiations of its agreements on the avoidance of double taxation (DTAs) has made fundamental changes to how favoured gateways are used for investing in India. Amelia Schwanke explores the catalysts that initiated the renegotiations and the new treaty structures that have replaced outdated policies.
Special features - February 2017

Read this month's special feature on Italy
Albania: Albanian parliament amends Law on Tax Procedures
Argentina and UAE sign double tax treaty

The tax treatment of transactions between Argentina and the UAE will change after the two nations signed a new agreement for the avoidance of double taxation (DTA).
Australia’s initial approach to the OECD BEPS Multilateral Instrument

Following the release of the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) on November 24 2016, the Australian government has released a consultation paper on the potential impacts of Australia becoming party to the MLI.
Bosnia and Herzegovina: Bosnia and Herzegovina amends rulebook on indirect tax control
Brazil: Brazil introduces several new tax measures
Canada: CbCR rules implemented in Canada
China’s environmental protection tax

China’s environmental protection tax introduces a new administrative framework that may change the tax burden for polluting enterprises.
Croatia’s tax reform measures enter into force

Croatia's reformed tax system made significant amendments to the VAT Act, including changes to the rates structure and re-categorising certain goods and services.
Cyprus: Cyprus’ commitment to the MCAA on CbCR
Georgia: Georgia and South Korea DTA applies from 2017
Hong Kong: Shenzhen-Hong Kong Stock Connect opens
Revision of India-Singapore Tax treaty; De-notification of Cyprus as a ‘notified jurisdictional area’

The changes brought about by the Protocol are largely similar to the revised India-Mauritius tax treaty.
Indonesia: New transfer pricing requirements in Indonesia
Ireland’s tax regime for real estate funds

Certain Irish investment funds will be exempt from corporation tax or income tax on their profits, but may face a withholding tax under recent legislative changes.
Malta issues MAP guidelines

The conclusion of double tax treaties has grown to become one of Malta's key international tax policies, but its experience with mutual agreement procedures (MAP) and alternative dispute resolution mechanisms is in its infancy.
Montenegro: Montenegro and Portugal sign DTA
More BEPS reforms to come in New Zealand

The New Zealand government has released a cabinet paper, prepared by the Ministers of Finance and Revenue, recommending further reforms to address base erosion and profit shifting.
Poland: Poland’s major tax changes for 2017
South Africa: South Africa tax amendments become effective in 2017
Spanish Supreme Court anticipates the effects of the BEPS Project

The Supreme Court has ruled that a dependent agent in Spain can constitute a PE of a foreign enterprise. The judgment said that activities have to be considered in the context of a globalised world where tax treaties have to be interpreted with wider international standards on tax.
Swiss Court upholds CHF 100 million import VAT adjustment

Swiss companies with cross-border supply chains need to check they fully comply with Swiss laws on VAT and importation after a recent case that went in favour of the tax authorities.
Turkey: Turkey offers tax free repatriation of foreign assets
US Inbound: Domestic disregarded entities: New reporting rules
Tax Relief
International updates - February 2017

The latest international updates from our correspondents around the world.