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Alexander Linn Earlier this year (see July update), Germany's Federal Constitutional Court held that the German change-in-ownership rules relating to loss carry-forwards partially infringe the German Constitution, and must be amended with retroactive effect. The judgment, however, only dealt with transfers of more than 25% and up to 50% of the shares in a company that has loss carry-forwards. According to the rules, such transfers result in a pro rata forfeiture of the tax loss and interest carry forwards, while a transfer of more than 50% of the shares results in a complete forfeiture of all available carry-forwards.

The OECD has continued to evaluate and work on refining its transfer pricing guidelines regarding several BEPS initiatives, write David Jarczyk and John Wiora of ktMINE.

Tahsin

International Tax Review honoured the best firms across the Americas at a ceremony in New York on September 14 2017.

Jim

Jorge Correa and Gerardo Farías of Creel, García-Cuéllar, Aiza y Enríquez discuss the proposal to amend the mandatory disclosure rule included in Mexico’s 2018 budget.

Angel

Many of us denizens of major Western metropolitan centres have been there at some point. A few light ales turn into a few more and before you know it you're standing in the queue for a kebab with the dawning realisation that the last train leaves in two minutes and you're never going to make it. You don't fancy the prospect of three buses so out comes the phone and you hit up the Uber app.

Lewis

The draft Taxation Laws Amendment Bill (DTLAB), released for comment on July 19 2017, contains a proposal to include a new section in the Income Tax Act to address structures that, in the view of the South African Revenue Service (SARS), are aimed at avoiding dividends tax on distributions made to foreign shareholders by local companies.