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  • 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.
  • 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.
  • 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.
  • Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquistion $10.4 billion Vantiv Inc Worldpay Group (United Kingdom) Skadden, Arps, Slate, Meagher & Flom Allen & Overy Acquisition $5.2 billion Walgreens Boots Alliance Rite Aid Corporation (Sale of 2,186 stores, related distribution assets and inventory) Sidley Austin; Weil, Gotshal & Manges Skadden, Arps, Slate, Meagher & Flom (Chase Wink); Jones Day Acquisition $2.8 billion Internet Brands WebMD Health Corp Simpson Thacher & Bartlett (Rob Holo and Sophie Staples) Shearman & Sterling (Ethan Harris and Ryan Au) Acquisition $2.2 billion (approx.) A wholly owned subsidiary of Royal Philips Holding USA Inc The Spectranetics Corporation Sullivan & Cromwell (Eric Wang and Michelle Lu)
  • Google triumphs, but its French tax woes are not yet over
  • Read this month's special features on tax technology and transformation, Mexico and New Zealand
  • Former managing director of State Street Bank and leading financial expert Avinash Persaud tells Salman Shaheen why he has designed a financial transaction tax (FTT) for Britain’s opposition Labour Party to help rein in the City of London.
  • Another day, another Donald Trump policy in tatters