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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

Georgia: Georgia and Liechtenstein DTA enters into force

Lopatina Irina Georgia has increased its portfolio of double taxation agreements (DTAs) to 54 countries after its treaty with Liechtenstein entered into force in late 2016.

February 28 2017

Special features - March 2017

Read this month's special feature on Mexico

February 28 2017

Luxembourg: Views on the Luxembourg tax reform

Raymond Krawczykowski Sustainability, justice, selectivity and competitiveness, were the hallmarks of Luxembourg's tax reform approved in December 2016. Amendments and targeted tax rate reductions, for both individuals and corporations, became effective on January 1 2017. The measures should help maintain Luxembourg's competitiveness as a location for companies to do business, but the government should continue to adopt additional tax reform measures to continue its progress.

February 28 2017

South Africa: The spectre of withholding tax on service fees finally laid to rest

Sean Gilmour With effect from January 1 2017, proposed legislation relating to a possible South African withholding tax on service fees was formally deleted and a long period of uncertainty around this issue finally came to an end.

February 28 2017

Australia: Australian government submits DPT Bill to parliament

Michael Yunan Following further consultation, final legislation to implement a diverted profits tax (DPT) in Australia has been introduced into parliament.

February 28 2017

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