Magazine
June 2017

Magazine Archive

The Brockman brief: Double taxation: Does it matter?

There is one topic that is seemingly silent by tax administrations, non-governmental organisations (NGOs), parliamentarians and international tax bodies: double taxation. Keith Brockman reviews the state of play and what can be done to help multinationals.
Deals of the month

See who has done the tax work on this month’s biggest deals
Australia gets even tougher on tackling MNE tax avoidance
Compliance burdens rise despite lower tax rates and more incentives
Diageo first to fall foul of UK DPT
UK losing billions from leaky online VAT laws
Chevron’s landmark loss against ATO sets a precedent
UK parties split over taxes

As the UK election approaches, the Conservatives, the Labour Party and the Liberal Democrats have presented their respective proposals on tax policy. Josh White examines the party manifestos.
Asia forum shows there is more to tax than BEPS

BEPS may have been first among the topics for discussion at International Tax Review’s Asia Tax Forum, but it was not the only subject on the list. As Ralph Cunningham reports, panellists and delegates were also keen to discuss issues such as anti-avoidance, dispute resolution and tax incentives in their own countries and elsewhere.
Talking to the OECD: Tech disruption in tax administration

Peter Green, head of the Forum on Tax Administration (FTA) Secretariat at the OECD shares his views with the Inland Revenue Authority of Singapore (IRAS) and International Tax Review on how technology is changing the status quo for many industries and tax administrations with the constant emergence of new technologies and rising taxpayer expectations.
Transforming tax – under pressure

Tax departments are feeling the heat. A tsunami of changes is causing them to rethink their purpose and review how they operate. Mark Body, director, tax transformation (financial services) at KPMG in the UK, considers how corporate tax leaders are adapting to the changes, and what the future is likely to hold for them and their teams.
GST in India: Learning from the Malaysian experience

India is about to embark on a landmark change to its indirect tax system by implementing a goods and services tax (GST) regime. Yvonne Beh, partner at Wong & Partners (a member firm of Baker McKenzie International) and Nishant Shah, partner at Economic Laws Practice, explore how India can learn from Malaysia’s implementation experience.
Special features - June 2017

Read this month's special features on Technology, Mexico and China
Using blockchain for transparent beneficial ownership registers

The OECD and the Financial Action Task Force (FATF) are considering how to improve implementation of the international standards on transparency, including on the availability of beneficial ownership information and its international exchange. Julia de Jong, Alexander Meyer, and Jeffrey Owens of the Global Tax Policy Centre at the Institute of Austrian and International Tax Law within the Vienna University of Economics and Business explore how blockchain technology could be used to achieve this goal.
The economics behind EU tax probes: What it means for you

Understanding competition economics can help multinationals and national authorities restore and maintain the legal certainty of tax rulings. In the first of a two-part series of articles, Carina Lange, senior consultant at CEG Global in the Netherlands, explains the approach the Commission is taking to assess whether tax rulings or systems distort competition and how it fits into the general economic assessment of state aid cases.
Asia Tax Awards 2017

Twenty-eight different firms, individuals and companies shared the prizes at the Asia Tax Awards in Singapore.
Brazil: Tax authorities issue guidance on the treatment of software as a service

The Brazilian tax authorities attempt to resolve the withholding tax treatment of payments in relation to software, which has been a controversial issue for several years.
Canada: Broadening the de facto control test could impact cross-border transactions

Proposed changes to the Income Tax Act (Canada) included in the 2017 Federal Budget expand the relevant factors to be used in determining when de facto control of a corporation exists.
Chile: Concept of beneficiary of a double tax treaty
China: First tax case decision by Chinese Supreme Court

China's first ever tax case opens the way for an increasing body of court case guidance and makes court appeals of tax cases an increasingly relevant option for taxpayer disputes.
Germany: Finance Ministry issues guidance on the use of a brand name within a multinational group

Companies need to be prepared to answer tax questions on brand names and the application of the hypothetical arm's-length test as the appropriate transfer pricing method for trade mark fees.
Greece: Administrative guidelines published on tax benefits of cross-border restructurings
India: Important Supreme Court decisions on tax

Two important judgments on tax matters have been pronounced recently by the Supreme Court.
Indonesia: Will the amendments to the Income Tax Law simplify the rules?
Ireland: Ireland’s cooperative compliance framework
Italy: New revision of the Italian Transfer pricing provisions on arm’s length principle
Malta: Incentives for Malta’s capital markets
New Zealand: Courts consider challenge to information requests issued at request of foreign tax authority
Norway: Proposed interest limitation rules may impact inbound investments
Poland: The benefits of operating in a special economic zone
Romania: Tax Incentives for companies performing research and development activities
Russia: Bilateral APAs offer new opportunities

The Russian transfer pricing rules (TP rules) enacted in 2012 provide the opportunity for taxpayers to conclude both unilateral and bilateral advance pricing agreements (APAs). However, no bilateral APAs have been concluded until now.
South Africa: SARS confirms zero dividends tax rate in Swedish-South Africa DTA
Spain: Would EU law preclude Spanish inheritance and gift tax legislation in relation to cases involving parties resident in third states?
Switzerland: The impact of currency fluctuations on the CbCR threshold
Turkey: New tax amnesty to be introduced
US Inbound: New IRS APA report shows significant decrease in APA requests
Tax Relief

Because tax doesn’t have to be taxing. A less-than-serious look back at some of the quirkier tax stories from the past month.
International updates - June 2017

The latest international updates from our correspondents around the world.