ITR Search | International Tax Review

India’s renegotiated DTAs creating investment diversions

India’s recent renegotiations of its agreements on the avoidance of double taxation (DTAs) has made fundamental changes to how favoured gateways are used for investing in India. Amelia Schwanke explores the catalysts that initiated the renegotiations and the new treaty structures that have replaced outdated policies.

Amelia Schwanke, January 25 2017

South Africa: South Africa tax amendments become effective in 2017

Dan Foster Significant changes will enter into force in South Africa in 2017 after parliament approved the annual tax amendments in December 2016, some of which are discussed below.

January 25 2017

Brazil: Brazil introduces several new tax measures

Fernando Giacobbo Ruben Gottberg Brazil has recently issued a series of measures that intend to encourage greater taxpayer compliance and ensure domestic rules align with international tax initiatives. Legislation published applies the concept of significant economic activity to Austrian holding companies, amends the rules on the service tax regime, implements CbCR and CRS rules, and introduces a tax regularisation programme.

January 25 2017

Constitutions: Could paying a ‘fair share’ of tax already be enshrined in law?

Politicians and campaigners are fond of saying that companies should pay their ‘fair share’ of tax, but the phrase is over-used and lacks legal meaning and backing, becoming little more than a cliché. However, new research has identified clauses in the Constitutions of 15 countries – including two of the G7 member states – which identify an obligation to contribute to the public purse. Joe Stanley-Smith explores how this could force companies to take more notice of the fair-share debate.

Joe Stanley-Smith, January 25 2017

The post-BEPS advantages of the Netherlands

Roelof Gerritsen and Ivo Kuipers, both partners at Atlas Tax Lawyers in the Netherlands, look at why the country will remain a prime location for multinationals and foreign investors as governments worldwide transition towards more harmonised tax rules in line with the OECD’s BEPS Project.

January 25 2017

Australia’s initial approach to the OECD BEPS Multilateral Instrument

Following the release of the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) on November 24 2016, the Australian government has released a consultation paper on the potential impacts of Australia becoming party to the MLI.

January 25 2017

Hong Kong: Shenzhen-Hong Kong Stock Connect opens

Khoonming Ho Ayesha Macpherson Lau The Shenzhen-Hong Kong Stock Connect cross-border share trading mechanism commenced operation on December 5 2016.

January 25 2017

Argentina and UAE sign double tax treaty

The tax treatment of transactions between Argentina and the UAE will change after the two nations signed a new agreement for the avoidance of double taxation (DTA).

January 25 2017

Croatia’s tax reform measures enter into force

Croatia's reformed tax system made significant amendments to the VAT Act, including changes to the rates structure and re-categorising certain goods and services.

January 25 2017

Malta issues MAP guidelines

The conclusion of double tax treaties has grown to become one of Malta's key international tax policies, but its experience with mutual agreement procedures (MAP) and alternative dispute resolution mechanisms is in its infancy.

January 25 2017

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