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February 2018 has seen many important Australian tax developments. These affect investment funds, investors, multinationals and their investments into and out of Australia.

The lower tax court of Cologne has ruled on the definition of the 'direct shareholding' requirement under the EU Parent-Subsidiary Directive (PSD) in a decision dated September 13 2017. The case involved the refund of withholding tax in a case where a foreign corporation was a partner in an asset-managing partnership that held shares in a German corporation. The court held that the interposition of an asset-managing partnership between the German dividend-paying corporation and its foreign corporate shareholder did not conflict with the direct shareholding requirement and, therefore, the 0% withholding tax should be applicable.

The government of Georgia is attempting to simplify the country's tax code after Georgia signed its association agreement (AA) deal with the EU in mid-2014. While major tax reforms regarding corporate income tax took place in 2017, Georgia continues to modify and update its tax system, bringing several updates into force at the beginning 2018.

On June 7 2017, Canada signed the OECD's Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI), which will affect more than 70 of Canada's existing tax treaties. With respect to treaty abuse, Canada has chosen to implement the minimum standard by adopting the principal purpose test (PPT) without adopting the simplified limitation of benefits. In addition, Canada filed a notification that it accepts the PPT as an interim measure and that it intends, where possible, to adopt a limitation-on-benefits provision, in addition to or to replace the PPT, through bilateral negotiations.

For months, Congress promoted the tax reform effort as being focused on simplifying the outdated and complex 1986 Tax Code. Tax reform, culminating in H.R. 1, did no such thing, at least where it applies to multinational US corporations. Nowhere is this more apparent than in section 951A, the tax on global intangible low-taxed income, or ‘GILTI’. Erik Christenson, partner at Baker McKenzie, and Monte Silver, senior counsel at Eitan, Mehulal & Sadot explain.

The Korean government recently promulgated a new presidential decree imposing additional requirements on the National Tax Service (NTS) with regards to documents seized during an unannounced tax audit or 'dawn raid'.

The Albanian legislative act which defines the general principles and rules for the preparation of accounting standards, financial statements and accounting records is the Law on Accounting and Financial Statements (Law No. 9228, dated April 29 2004).

An amendment to Bulgaria's VAT Act has been adopted concerning the provision of supplies in stages. If an agreement for a supplier to deliver in stages specifies so, then each completed stage will be considered a separate supply. This amendment applies to the supply of services as well as to goods.

The purchase of goods and services from foreign sellers will now attract GST On February 19, Heng announced his budget to Parliament with the aim of dealing with three major shifts in the coming decade:

It is widely accepted that the tax treatment applicable to trusts in Spain is undefined. For this reason, it is necessary for the particular facts and circumstances of each trust to be considered in order for an accurate assessment of the Spanish tax implications to be prepared. However, from time to time, the Spanish tax agency (Agency) provides certain insights into the tax treatment applicable to trusts through its formal reply system to taxpayer consultations.