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  • According to the law on clean air, adopted by the Iranian Parliament on July 16 2017, Mohammad Masihi, an official from the tax administration, stated that all home-grown, eco-friendly, zero-emission hybrid and electric cars and motorcycles will benefit from a tax exemption.
  • The Australian Treasurer Scott Morrison released exposure draft legislation on November 24 to prevent entities that are liable to Australian income tax from avoiding income taxation or obtaining a double non-taxation benefit by utilising differences between the tax treatment of entities and instruments across different countries.
  • The German tax legislator made only a few substantial changes to the tax rules relevant for international business during 2017, the notable exception being the introduction of a new rule that will limit the deductibility of royalty payments made to recipients benefiting from a non-nexus intellectual property (IP) regime, which will apply from 2018 (see March issue of the International Tax Review magazine). In addition, the German courts issued some decisions that will require the legislator to introduce new rules, such as the replacement of the restructuring relief previously granted under an administrative practice based on a circular (see April issue of the International Tax Review magazine) and new change-in-ownership rules (discussed below). Most other changes to the tax code addressed procedural issues, such as increased notification requirements for certain business relationships with third countries and certain reliefs, by increasing the thresholds that allow simplified approaches to depreciation/amortisation, documentation, etc.
  • The Brazilian National Congress approved a protocol on October 5 2017 that amends the double tax agreement (DTA) between Brazil and Norway in order to improve the exchange of information between the competent authorities of both contracting states.
  • A suite of mutually reinforcing measures with an overall focus on resolution at the earliest point in time is the ultimate goal for taxpayers and tax authorities. Achim Pross, Sandra Knaepen and Mark Johnson of the OECD describe the organisation’s comprehensive dispute resolution agenda, both within and beyond the BEPS project.
  • For the past couple of years, many commentators have used the term “disruption,” sometimes without much forethought, writes Carolyn Bailey, Americas digital tax administration services leader at EY. It sells newspapers, magazines and journals, and it attracts television viewers.
  • There are a number of colliding dynamics which will lead governments worldwide to undertake drastic measures on VAT and other taxes in 2018, resulting from namely Brexit, VAT fraud, austerity straitjackets and global tax wars, writes Richard Asquith, vice president of global indirect taxes at Avalara.
  • Overall, 2017 saw significant changes in Chinese tax rules and in the broader regulatory environment. Many of the changes reflected the reorientation of government policy towards an evolving cross-border investment landscape. The digitisation of the economy, as well as the tax administration, was also a key driver of developments.
  • Generally, a gain realised by a non-resident of Canada on the sale of shares of a corporation that derive more than 50% of their value from Canadian real property (CRP), being real properties or resource properties situated in Canada, at any time in the 60 months preceding the sale is subject to tax in Canada. Such shares are known as "taxable Canadian property" (TCP). Exceptions exist for holdings of shares listed on a designated stock exchange where the holder owns less than 25% of any class of shares of the issuer and under the provisions of certain tax treaties. On May 1 2017, the Canada Revenue Agency (CRA) released a Technical Interpretation (TI) (2015-0624511I7) describing the approach that should be followed to make the 50% determination if the property of the corporation (Parentco) includes shares or debt of a wholly-owned subsidiary corporation (Subco). Although the TI addresses a prior version of the TCP definition, the comments appear to be applicable to the current definition, which employs essentially identical language relating to derivation of value.
  • The concept of corporate legal migration, i.e. the change of domicile of any legal entity, is not included in the Chilean tax law. Thus, its effects depend on the concept of legal residency given by the country from which the company migrates, as well as by the country to which the company moves to.