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Facebook and Microsoft have been forced to change their operating structures in Australia to avoid being caught by tough tax avoidance laws, but could simply amending tax rates and incentivising R&D investment change corporate behaviours voluntarily?

Tax risk is a modern ‘term of art’ perception; this risk can be viewed as a pendulum. Keith Brockman looks at the advantages of corporate collaboration and threats of uncertainty and public distrust.

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.

The Netherlands is the world’s leading conduit offshore financial centre

Tiago Cassiano Neves Dinis Tracana The Portuguese tax authorities (PTA) issued a ruling on July 21 2017 that has the novelty of providing for the first time some guidance on the interpretation of the permanent establishment (PE) concept for corporate income tax (CIT) proposes in the framework of some operating models. The following is a brief summary of the facts and conclusions underpinning this ruling.

Alexander Tokarev Ivan Nasonov In 2015, the 'beneficial owner of income' concept was introduced into the Russian Tax Code. Since 2017, foreign companies claiming treaty benefits in Russia are obliged to provide the Russian companies paying them income with documentary proof of their status as beneficial owners of this income.

Jim Fuller David Forst The US Tax Court, in Grecian Magnesite Mining, Industrial & Shipping Co, SA v. Commissioner, 149 TC No. 3 (July 13 2017), held that a constructive sale by a foreign person of its interest in a partnership engaged in a US trade or business was not subject to US tax. In so doing, the court dismissed the conclusion of Revenue Rule 91-32 (Rev. Rul. 91-32) that a gain on the sale by a non-US partner of its interest in a partnership should be analysed asset-by-asset and treated as income effectively connected with the conduct of a trade or business (ECI) to the extent the partnership's underlying assets are used in a US trade or business. This ruling has been subject to heavy criticism since it was issued as not being in accordance with the Code and Regulations. The court's holding validates that criticism and positions taken by foreign taxpayers in accordance with the Code and Regulations rather than Rev. Rul. 91-32.

Benno Suter Tomáš Rodák Based on a partial revision of the current Swiss VAT Law (VAT-L), foreign domiciled companies selling into Switzerland will be treated the same as companies domiciled in Switzerland.

Isabel Reis The budget law for 2017 (Law No. 42/2016 of December 28 2016) introduced a new VAT regime that provides rules for the payment of VAT due on the import of goods by self-assessment through the corresponding periodic return. The procedure to follow for its application is established in Ordinance 215/2017, of July 20.