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Brazil: New taxable services and tackling harmful tax competition

Supplementary Law 157/16 regarding the municipal service tax (ISS) was brought in to allow the taxation of new services and to reduce the harmful tax competition between municipalities.

February 28 2017

Inside M&A: Welcome to the Tax Transactional Survey 2017

International Tax Review’s flagship tax transactional feature looks at the global M&A market during 2016, explores the tax trends in major deals that may continue into 2017, and provides a breakdown of the leading firms in transactional advice across multiple jurisdictions.

February 28 2017

Greece: When is it the right time for fiscal stimulus?

How can the right time for fiscal stimulus be determined if there are persistent austerity measures, causing a lack of local demand for the services and products that a country offers?

February 28 2017

Deals of the month

See who has done the tax work on this month’s biggest deals

February 28 2017

The Brockman brief: Tax haven blacklist: Talk of the town

As EU member states determine the criteria for what constitutes a tax haven, while at the same time lowering their tax rates, the debate over tax havens is growing. Keith Brockman considers the parameters of the ideas of ‘transparency’ and ‘tax haven blacklist’.

February 28 2017

Editorial

Mergers and acquisitions work is the lifeblood of many tax practices and the market has recovered since the lows of the financial crisis. A flurry of large deals in late 2016, including the $108 billion AT&T purchase of Time Warner, meant 2016 was the second-busiest for deal making since the crisis, but how will the M&A market respond to political upheaval across the globe?

February 28 2017

China: Tax implications of China’s regulatory rules on cross-border leverage

Khoonming Ho Lewis Lu The People's Bank of China (PBOC) issued PBOC Circular 9 [2017] on January 12 2017. This makes important changes to the regulations determining how much leverage Chinese enterprises, including foreign invested enterprises (FIEs), can take on through cross-border borrowing into China.

February 28 2017

Transfer pricing adjustments in Mexico

Mexican tax rules dealing with transfer pricing adjustments entered into force on January 1 2017. These rules deal only with primary adjustments and all the formalities related to them, especially those to meet the requirements for deductions. Primary adjustments can even be recognised on a cashless basis. Unfortunately, at this stage secondary adjustments are not covered in these rules. Ricardo Rendón and Yoshio Uehara explain the changes.

February 28 2017

Brazil: Brazil releases guidance on applying withholding tax on payments for software licences

Fernando Giacobbo Mark Conomy The Brazilian tax authorities (RFB) issued Solução de Consulta No. 154/2016 on November 18 2016, which states that payments in relation to the right to duplicate and commercialise certain software should be subject to Brazilian withholding tax (WHT).

February 28 2017

Germany: Germany proposed limitations on tax deductibility of royalty payments

Alexander Linn Thorsten Braun The German government decided on January 25 to introduce a bill into the legislative process that would limit the deductibility of royalty payments between related parties for payments that become due after December 31 2017.

February 28 2017

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