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With a general election looming, the New Zealand government has unveiled a raft of measures intended to counter base erosion and profit shifting (BEPS) that, in some respects, go further than any of the OECD’s BEPS recommendations. Brendan Brown and Tim Stewart of Russell McVeagh in New Zealand explain the recent announcements, which include measures to address permanent establishment avoidance, significant changes to the transfer pricing and thin capitalisation rules, measures to address hybrid mismatch arrangements, and various measures (going beyond the OECD’s BEPS recommendations) to increase Inland Revenue’s enforcement powers.

As disruption layers new complexity, pressure and opportunity onto business, the digital tax function is rapidly evolving. Shawn Smith, EY global tax technology and transformation leader, explores the needs of organisations as these developments occur.

Ian Caines Bill Maclagan On June 7 2017, Canada was among 68 countries to sign the OECD's Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI). The MLI is an instrument developed as part of the OECD's project on base erosion and profit shifting (BEPS), in order to allow participating countries to efficiently implement BEPS recommendations in their tax treaties, without needing to individually renegotiate each treaty.

Ignacio Rodríguez On July 21 2017, a new amendment protocol to the double tax treaty (DTA) between Argentina and Brazil was signed. The subsequent exchange of instruments of ratification, which is expected to occur soon, will make it effective from January 1 of the year following the completion of this ratification process.

Melissa Lim The Australian Tax Office (ATO) has released a draft practical compliance guideline (PCG 2017/D4) (the guideline) on its compliance approach on transfer pricing issues associated with related party cross border financing arrangements. This guideline, once finalised, will have effect from July 1 2017 and will apply to existing and newly created financing arrangements. This guideline is not intended to constitute technical advice or guidance. Rather, this guideline is a risk assessment framework tool that sets out how the ATO will assess compliance risk attaching to cross-border related party financing arrangements and invites companies to self-assess their compliance risk.

Maria Nicolaou Anastasia Sagianni As of July 1 2017, the tax treatment of intra-group financing arrangements has been amended in Cyprus.

Astrid Schudeck Gregorio Martínez For a significant amount of years, Chilean taxpayers have preferred life insurances with savings over other saving mechanisms. Until now, it was always understood within the market that no tax impact derived from this type of savings tool.

Alexander Linn The Tax Court of Cologne has referred three separate cases regarding the application of Germany's anti-treaty shopping rules to the Court of Justice of the European Union (CJEU). The court questions whether the rules are compatible with the freedom of establishment principle in the Treaty on the Functioning of the European Union (TFEU) and/or the EU Parent-Subsidiary Directive.

Maria Anastasiou Afrodita Taci Transfer pricing legislation was introduced in Croatia by way of the Corporate Income Tax Act (CIT) on January 1 2005. However, the Croatian tax authorities have only recently recognised its importance, with advance pricing agreements (APAs) recently being implemented in Croatian tax legislation.

Spain has introduced groundbreaking requirements for companies to file transactional data in near real-time. Joe Stanley-Smith examines the case study of global battery company Duracell to explore how companies are dealing with the extra workload from the Suministro Inmediato de Información (SII) legislation, one month on from its implementation on July 1 2017.