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Jasper Korving and Loes van Hulten of Deloitte provide an overview of the MLI, focusing in particular on the principal purpose test (PPT), an anti-treaty abuse measure in the convention, how the PPT might apply in practice, and its potential impact on companies.

The taxpayer challenges arising from the EU’s directive on mandatory disclosures for intermediaries (DAC 6) are seemingly countless, writes Christian Kaeser, global head of taxes at Siemens, and Mark Orlic and Arne Schnitger of PwC.

On October 9 2018, Ireland's Minister for Finance, Public Expenditure and Reform Paschal Donohoe announced budget 2019. On October 18 2018, the draft legislation to implement the budget was published. In furtherance of Ireland's obligations under the EU Anti-Tax Avoidance Directive (ATAD), Donohoe announced the introduction of a new controlled foreign companies (CFC) regime and an ATAD-compliant exit charge. The exit charge took effect from October 10 2018 and the CFC rules will apply to accounting periods beginning on or after January 1 2019.

Tax transparency and governance has moved up in the hierarchy of key topics and risks for the C-suite to monitor and manage. Tax has changed from simply just being in the exclusive realm of the tax director and being a compliance concern for multinationals, to becoming the more consequential strategic matter it is today. How you communicate on where and how you pay your taxes, and what your narrative is in terms of tax strategy and corporate social responsibility, has become increasingly important. This is due to the large increase in tax transparency requirements that have been mandated at international, EU and national levels. This trend started in 2012 and has intensified since revelations such as 'LuxLeaks', as well as the Panama and Paradise Papers. However, there are still quite a few CEOs, CFOs and tax directors – as well as tax advisors and others – who expect that the current transparency drive will soon blow over post-BEPS. So which one is it for tax transparency? Are we at the beginning of the end, or at the end of the beginning?

On November 2 2018, Hong Kong's new research and development (R&D) regime was enacted and applies to eligible expenditure incurred on or after April 1 2018.

Recent developments have increased the likelihood of New Zealand considering a tax on digital services.

On August 31 2018, the revised IIT Law was passed by China's Parliament, the National People's Congress (NPC). The revised law will come into full effect from January 1 2019. In advance of this, revised IIT standard personal deductions and tax rates tables have applied from October 1 2018. Following on from this, on October 20 2018 the Ministry of Finance (MOF) and the State Administration of Taxation (SAT), released draft IIT Law implementation rules, as well as the draft guidance on itemised deductions thresholds, both for public consultation. The consultation period has now ended but the final rules are still to be released.

The tax authority under a formal and strict application of such criterion has rejected expenses that were perfectly reasonable from a business perspective.

On October 2 2018, the EU Council agreed to adopt several proposals from the European Commission to reform the EU VAT system. These proposals included four 'quick fixes' to the prevailing regime that will apply to improve the functioning of the existing VAT system, pending the introduction of the 'definitive' VAT system that is still the subject of continuing discussion.

In April 2018 the Federal Tax Service of Russia issued a letter (Letter No. CA-4-9/8285@) containing guidelines for lower tax authorities on how to use the beneficial ownership concept when applying treaty benefits in Russia.