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“In China and Brazil, they’re concerned they will lose positions in arbitration which they can now afford to keep up because there’s no one to punish for their errors” Pascal Saint-Amans, director of the Centre for Tax Policy and Administration at the OECD, has said that progress needs to be made on the arbitration element of the organisation's base erosion and profit shifting (BEPS) action plan.

In the first of his regular monthly updates, Keith Brockman, global tax director at Mars, lecturer and author of the Strategizing Multinational Tax Risks blog, looks at why countries are enacting unilateral legislation to limit interest deductibility, the shift in focus from eliminating double taxation to eliminating non-taxation, and why, as a result, double taxation via interest limitations is here to stay.

Taxpayers should beware of the knotty problems that can result from the supply of services by a non-resident to a New Zealand resident, explains Tim Stewart of Russell McVeagh.

Competitive tax regimes and tax-planning strategies have been increasingly in the spotlight over the past 18 months or so, and the international tax landscape is changing. Louise Kelly, tax partner at Deloitte, looks at recent tax changes and assesses how Ireland is positioned after the abolition of the infamous ‘Double Irish’.

Read this month's special features for North America and Ireland

The oil industry has been questioned several times by the Brazilian tax authorities regarding agreements covering oil and natural gas exploitation services, including the prospection and concurrent charter of offshore platforms.

Philippe Jeffrey

Robert Kopstein

Joseph Hong Recently, the number of free trade agreement-related disputes has increased in Korea, and many cases involve country-of-origin verification by the customs authority of the exporting country under what is called an 'indirect verification regime'. In this regime, the customs authority of the exporting country conducts origin verification at the request of the customs authority of the importing country, and the FTAs adopting this regime usually require that the reply from the exporting country must be provided within a certain period and the reply must contain detailed information related to origin determination unless there are exceptional circumstances. However, the term 'exceptional circumstances' has been very narrowly interpreted by Korean courts and, as a result, importers are being punished for the failure by the customs authority of the exporting country to comply with the requirements under the FTAs. In 2014 Guhap 51777 (November 25 2014), the Seoul Administrative Court held that the unavailability of relevant documents due to a short document retention period under the law of the exporting country is not one of the exceptional circumstances which justifies non-compliance with the requirements under the relevant FTA. In this case, the importer at issue (Company N) is a Korean subsidiary of a Swiss-based multinational pharmaceutical company. In 2007 and 2008, Company N imported pharmaceutical products from a Swiss company. Preferential duty rates under the Korea-EU Free Trade Agreement (EU FTA) were applied based on the certificate of origin issued by the exporter.

UK tax code dwarfs literary texts The past month has seen some intense parliamentary scrutiny of the UK revenue authorities and, by extension, the British tax system, and one interesting fact Tax Relief pulled out is that the country's tax code is more than 17,000 pages long. If you were to add the total page-count of the Bible, the Qur'an and the Bhagavad Gita – sacred texts of the world's three largest religions – you would have less than a fifth of the pages of the UK's tax legislation. To account for secularism, throw in War and Peace by Leo Tolstoy and all seven Harry Potter books by Joanne Rowling and you'd still only be around half way there.