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  • Raoul Stocker Jonathan Belet On November 23 2016, the Federal Council adopted the Federal Act on the International Automatic Exchange of Country-by-Country Reports of Multinationals (the Act) that aims to implement the country-by-country reporting (CbCR) standard in Switzerland as recommended by the OECD as part of the BEPS project. The Council of States passed the Act on March 16 2017 and the National Council will discuss the draft legislation in June 2017. If the Parliament (i.e. the Council of States and the National Council) approve the proposal and a referendum is not held, the Act should enter into force at the end of 2017.
  • UK multinational and alcoholic drinks producer Diageo is the first company that will have to make an upfront tax payment to UK tax authority, HMRC, before it can challenge preliminary notices of assessment issued under the diverted profits tax (DPT) regime.
  • The role of technology and digital tools in taxation is growing. Jon Dobell, EY global compliance and reporting leader in the tax group, discusses the power of technology and how it will change tax functions in the future.
  • As the UK election approaches, the Conservatives, the Labour Party and the Liberal Democrats have presented their respective proposals on tax policy. Josh White examines the party manifestos.
  • The OECD and the Financial Action Task Force (FATF) are considering how to improve implementation of the international standards on transparency, including on the availability of beneficial ownership information and its international exchange. Julia de Jong, Alexander Meyer, and Jeffrey Owens of the Global Tax Policy Centre at the Institute of Austrian and International Tax Law within the Vienna University of Economics and Business explore how blockchain technology could be used to achieve this goal.
  • During the OECD Ministerial Council Meeting, which is to be held in Paris in the week beginning June 5 2017, Mexico will finally make public its stance on Mandatory Binding Arbitration, write Alejandro Torres Rivero and Andrea Obregón Widmer of Chevez, Ruiz, Zamarripa y Cia.
  • The Brazilian tax authorities attempt to resolve the withholding tax treatment of payments in relation to software, which has been a controversial issue for several years.
  • Anne Bennett In a binding private ruling, dated March 1 2017, the South African Revenue Service (SARS) confirmed that as a result of the most favoured nation (MFN) clause in the double tax treaty held between South Africa and Sweden, South African dividends tax is not payable on dividends declared by a local company to a Swedish resident shareholder.
  • The Russian transfer pricing rules (TP rules) enacted in 2012 provide the opportunity for taxpayers to conclude both unilateral and bilateral advance pricing agreements (APAs). However, no bilateral APAs have been concluded until now.
  • The Council of the European Union has acted on BEPS Action 2 after adopting a directive to clamp down on the use of hybrid mismatch arrangements and halt corporate tax avoidance, but this could result in uncertainty for businesses.