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New Zealand has been active in implementing measures to address BEPS. Brendan Brown and Joshua Aird of Russell McVeagh in New Zealand explain the latest proposals that include measures to address permanent establishment avoidance, significant changes to the transfer pricing rules and an interest rate cap (among other measures) to limit related party interest deductions.

Khoonming Ho Lewis Lu The 5th session of China's 12th National People's Congress (NPC) commenced on March 5 2017 and several senior government officials highlighted a number of tax policy priorities for 2017 in addresses to the NPC and in press events on the sidelines of the NPC meeting.

The US tax system is on the brink of change as upcoming discussions centre on tax policy (including regulations related to inversion transactions) that will ultimately reshape the US tax treatment of inter-company financing within MNEs. In the second half of 2016, a stream of new regulations and law changes, both actual and proposed, in and outside of the US, created new issues for inter-group financing by multinationals. Stuart Chessman, director at Vivendi, discusses the salient points.

Barbara Scampuddu Gian Luca Nieddu Starting from 2017, non-resident individuals who transfer their place of residence to Italy may opt for a preferential tax regime with regard to foreign source income.

Jacques Kistler Rene Zulauf After the rejection of Corporate Tax Reform III (CTR III) by the Swiss electorate on February 12 2017, the Swiss Federal Council now plans to introduce revised legislation of the tax reform quickly and has instructed the finance ministry accordingly.

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.

There has been a complete paradigm shift in global taxation with the rise in audit risks caused by new global initiatives like the OECD’s BEPS Project. JD Choi, CEO at Tax Technologies, explores the technology solutions that should be administered to mitigate these audit risks in a post-BEPS world.

Lopatina Irina Georgia is becoming an increasingly popular jurisdiction for investments and export – import transactions with Commonwealth of Independent State (CIS) and EU countries. Among other factors, the attractiveness is also due to the absence of strict currency control rules and the availability of free trade regimes with European and other foreign countries. Additional advantages include the absence of corruption, the transparent conditions of conducting business, the signed association agreement with the EU, the introduction of a visa-free regime with the EU, the six fixed taxes and lowered tax rates, the significantly shortened list of licenses and permits, as well as simplified administration procedures. Georgia is among the top ranked countries in the World Bank's list on the ease of doing business. In addition, Georgia has significantly succeeded in establishing a business-friendly environment and maintaining a healthy, comfortable and attractive investment climate for foreign investors. In this regard, it is specifically worth mentioning the attractive investment opportunities in the Georgian free industrial zones (FIZ) regulated by the Law of Georgia on Free Industrial Zones, which aims to promote economic growth, enhance industrial competitiveness and attract foreign direct investments.

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.

Dorina Asllani Ndreka Albania and Iceland signed an agreement for the avoidance of double taxation and the prevention of tax evasion regarding income tax (DTA) on September 26 2014, which was ratified by both countries and entered into force on January 6 2016. Under the treaty provisions, its general implementation has begun as of January 1 2017.