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The Canadian government looks set to implement new foreign affiliate dumping rules, but the proposals go further than expected and, if enacted without alterations, would impose severe limitations on Canadian taxpayers, explain Ian Crosbie and Raj Juneja, of Davies Ward Phillips & Vineberg LLP.

See who has done the tax work on this month’s biggest deals

Until last year, France used to be a tax-friendly country for loss making enterprises. Sonia Bonnabry of LEXCOM explores why this is not necessarily the case anymore, following the tightening of French rules in the second Amended Finance Bill for 2012.

David Jamieson of Baker & McKenzie looks at whether the door is open again for further VAT rebates after the GMAC/BT case.

Cédric Tussiot and Joachim Bailly look at intermediation in the sale of shares of real estate companies in Luxembourg and whether VAT should be applied, based on the recent European Court of Justice case for broker firm DTZ Zadelhoff vof.

Multinationals are clambering over one another to try to establish themselves in Brazil, confident of the rich rewards such investment could reap while the country continues to harbour one of the world’s fastest growing economies. But how is Brazil’s tax administration coping with this changing business landscape? In an exclusive interview, Joe Dalton speaks with Monica Calijuri, Commissioner of the Federal Revenue of Brazil’s Large Business Office in São Paulo, to find out what part the tax authorities are playing in bringing more investment to Brazil.

To route their investments in a tax efficient manner, investors in the EU often use special purpose vehicles (SPV) incorporated in a third-party jurisdiction. The preferred jurisdictions are generally Luxembourg, the Netherlands, and, to a lesser extent, the UK or Switzerland (which benefits from certain EU directive rules under EU-Swiss agreements). Antoine Vergnat of McDermott Will & Emery in Paris provides a practical description of the main substance-related requirements that SPVs must satisfy to benefit from exemptions or reductions of withholding taxes on portfolio incomes derived from EU operating companies (which assets are not predominantly made up of real estate assets).

The OECD released a number of reports relating to transfer pricing recently. The draft on intangible assets was released ahead of schedule in June, but the organisation has also produced a draft on safe harbours and memorandums of understanding and another on timing issues. Sophie Ashley considers the practical implications of these reports.

Thomas Durham, Brian Kittle and William Schmalzl of Mayer Brown explain why section 6676, the recently enacted refund penalty that imposes a penalty on the filing of certain refund claims, is hitting taxpayers hard.

Antonio Tomassini and Alessandro Martinelli, of DLA Piper, analyse a recent Italian circular which gives clarity on mutual agreement procedures (MAP) and look at how its guidelines will interact with domestic law.