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The tax status and characterisation of passive holding companies has gained renewed interest with Article 7 of the OECD’s Multilateral Instrument (MLI) containing some reference to these entities. Mauro Manca of Giovannelli e Associati looks at how these structures can still work if there are sound organisational reasons in the MNE structure.

The tax regimes governing the gig economy, combined with the rules on self-employed individuals, have led to the success of companies such as Uber and Deliveroo. However, the Taylor Review on modern working practices has suggested radical changes that could change it all and stop other sectors adopting similar practices. Anjana Haines talks to the report’s author, Matthew Taylor, to discuss his recommendations and what they could mean for the future of the gig economy.

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.

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.

Irina Lopatina On June 22 2017, the parliament of Kyrgyzstan approved the bill ratifying the tax treaty signed with Georgia on October 13 2016. Currently, the ratification from the Georgian side is still pending, and in order to become law and to be ratified, the bill still needs to be signed by the presidents.

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.

Samar Abdel Rahman The Egyptian Minister of Finance Amr El Garhy has announced that the VAT rate will increase by one percentage point, effective July 1 2017. The general VAT rate will now be 14% instead of 13%, subject to the provisions of the Egyptian VAT Law No. 67/2016.

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

Fernando Giacobbo Ruben Gottberg On July 27 2017, the Brazilian tax authorities published Normative Instruction 1.722/2017, clarifying that Brazilian affiliates of non-Brazilian multinational enterprises may be required to file the country-by-country report (CbCR) in Brazil, in relation to the fiscal year 2016, even if a CbCR has been filed by either the ultimate parent entity (UPE) or a surrogate entity (SE) in another jurisdiction.