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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.

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.

Ilias Sakellariou The Greek Independent Authority for Public Revenue (IAPR) published on July 24 2017 a decision (POL. 1114/2017) to provide administrative guidance on the Greek tax treatment of foreign trusts and foundations.

Magdalena Zamoyska From 2018 Polish companies will not be allowed to deduct costs of their capital investment activity from operational revenue.

Abigail Blanco The Spanish Central Economic and Administrative Tribunal (TEAC) and State Tax Agency (AEAT) recently concluded that an invitation to a medical practitioner to attend a medical seminar means that they obtain income in kind.

Mark Galea Salomone Donald Vella The guidelines issued in relation to the implementation of EU Council Directive 2014/107/EU of December 9 2014, amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation (DAC2), in Malta and the common reporting standard (CRS) were updated on July 6 2017. Specifically with respect to trusts, the Commissioner for Revenue has introduced clarifications to the guidelines, which the Inland Revenue Department has deemed necessary for the purposes of a more correct application of the regulations.

Anne Bennett Proposed changes to the Income Tax Act, contained in the 2017 draft Taxation Laws Amendment Bill (draft TLAB), were released for comment on July 19 2017. This article discusses some of the international tax related proposals. The amendments discussed below, other than the last one, will, if enacted, apply in respect of tax years starting on or after January 1 2018.

Burçin Gözlüklü Ramazan Biçer Guidance that details how the Turkish tax authorities will determine whether to call a taxpayer to justify his declaration before initiating a tax audit have finally been released, almost year after this new mechanism was put in place.

Mark Martin Mark Horowitz On July 26 2017, the US Tax Court issued a memorandum opinion in Eaton Corp. v. Commissioner, TC Memo 2017-147 that concluded, in part, that cancellation by the IRS of advance pricing agreements (APAs) was an abuse of discretion.

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.