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  • The world is on the cusp of a major tax revolution as cryptocurrencies and online distributed ledger technologies, such as blockchain, push financial systems from the physical world to online. Amelia Schwanke speaks to the experts in a roundtable discussion about the tax implications and usage of digital currencies and blockchain.
  • Jim Fuller David Forst A fundamental principle of US transfer pricing rules is that transactions structured between related parties are to be respected unless the transactions lack economic substance (see Treasury Regulations §§ 1.482-1(d)(3)(ii)(B) and (iii)(B)). This is an important rule that respects a central pillar of the US tax system – separate entities should be treated separately. The rule also contributes to predictability and stability in worldwide tax administration.
  • Alexander Linn Thorsten Braun The German Federal Tax Court has ruled that the existing administrative practice on the exemption of certain tax technical gains, triggered in restructurings of companies facing difficulties, lacks a legal basis and cannot be applied any longer (case: GrS 1/15). Shortly after the judgment, however, the German legislator introduced draft provisions that would reinstate the past administrative practice.
  • The first agreement on the avoidance of double taxation and prevention of fiscal evasion between Hungary and Iran entered into force on January 1 2017. Iran has concluded more than 40 tax treaties, but very few of them provide for zero withholding tax rates on rental income and consulting fees. Thus, this specific tax treaty can be a good platform for multinationals looking to invest into Iran.
  • Bob van der Made EU member states sent a letter on February 1 2017 to 92 jurisdictions outside the European Union, informing them that they will be "screened" with a view to possible inclusion in a future EU "blacklist" of tax havens. According to the EU's tax policy calendar, the common EU blacklist should be ready by the end of 2017, which, given the task, seems quite ambitious.
  • The Brazilian tax authorities (RFB, under its Portuguese acronym) issued Normative Instructions (NIs) and a tax ruling in recent months that will help companies operating cross-border to understand the authorities' position.
  • Countries worldwide have followed Mexico’s lead to tax sugar-sweetened drinks in an effort to curb obesity and unhealthy habits, but these measures are coming at a cost to manufacturers and may not be as profitable for governments as they suggest.
  • Everyone's heard of Bitcoin and the overnight millionaires the cryptocurrency made. But it is the technology that underpins it, which includes blockchain, which could really shake up the tax world. Could it one day eliminate the need for advisers? Might it spell the end of country-by-country reporting, data leaks and the need for audits?
  • Gonzalo Gallardo At the end of 2016, a provision appeared in Royal Decree-law 3/2016 of December 3, introducing important changes to the Corporate Income Tax Law. Prior to that, Royal Decree-law 2/2016 of September 30 2016, had amended the prepayment system relating to this tax, establishing a minimum advance payment based on the income per books rather than the tax base. Both of those provisions are aimed at reducing the public deficit by immediately increasing the amount collected for corporate income tax, and mainly affect companies with high revenues and multinationals operating in Spain (large enterprises). In this commentary, we will highlight the three most relevant changes brought in by the new provision.
  • Because tax doesn’t have to be taxing. A less-than-serious look back at some of the quirkier tax stories from the past month.