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The Supreme Court recently held that a UK holding company was the beneficial owner of dividends it received from a Korean taxpayer for purposes of the Korea-UK income tax treaty (the treaty). The court reached its decision despite the existence of certain facts that put the taxpayer at a disadvantage when looking at earlier beneficial ownership decisions that applied the substance-over-form doctrine in a treaty context.

The UK's new legislation to tackle hybrid mismatches, which enters into force on January 1 2017, may impact certain Swiss principal structures that are benefitting from a so-called Circular No. 8 regime.

Taiwan is to become the latest country to levy a VAT on online foreign retailers, following similar OECD-inspired laws introduced by the EU and countries including Japan, Russia, South Korea, Australia and New Zealand.

Bulgaria fully applies the OECD Transfer Pricing (TP) Guidelines and has had robust TP rules for several years.

Type of Deal Value Acquirer Target dviser to acquirer (tax) Adviser to target (tax) Merger $36 billion PotashCorp Agrium Stikeman Elliott; Jones Day Blake, Cassels & Graydon; Norton Rose Fulbright; Paul, Weiss, Rifkind, Wharton & Garrison; Latham & Watkins Merger $13 billion Waste Connections Progressive Waste Solutions Locke Lord; Bennett Jones Stikeman Elliott; Weil, Gotshal & Manges Acquisition $10 billion Avolon Holdings CIT Commercial Air Weil, Gotshal & Manges; Freshfields Bruckhaus Deringer Wachtell, Lipton, Rosen & Katz Acquisition $6.3 billion Endurance Specialty Holdings Sompo Holdings Skadden, Arps, Slate, Meagher & Flom: Sally Thurston Davis Polk & Wardwell Acquisition $3.2 billion Bats Global Markets CBOE Holdings Davis Polk & Wardwell: Neil Barr Sidley Austin Acquisition $2.7 billion LANXESS Chemtura Corporation Skadden, Arps, Slate, Meagher & Flom: Eric Sensenbrenner Davis Polk & Wardwell: Neil Barr 2 x Acquisitions $2.4 billion China Three Gorges; I Squared Capital Advisors Duke Engergy

The OECD BEPS Actions will result in a higher effective tax rate (ETR) and cash tax liability for most multinationals, whereas investors will continue to strive for lower ETRs and cash tax liabilities in the companies they consider for investment. Keith Brockman looks at where the balance should be in this equation, and who should be the master negotiator.

Brazil’s retail sector is shrinking, but governments want more revenue, so where does that leave businesses? The tax chief at international fashion retail company C&A talks to Amelia Schwanke about the changes taking place in the notoriously complicated tax jurisdiction.

Brazilian tax authorities (RFB) issued Normative Instruction 1,658/2016 (NI 1,658) that includes Ireland in the list of tax havens (the black list) and also adds the regime applicable to Austrian holding companies to the list of privileged tax regimes (the grey list).

The Indonesian tax authority has spent the past few months conducting an investigation into Google's tax affairs through the company's office in Indonesia. However, Google's parent company, Alphabet, is arguing that Google does not have a permanent establishment (PE) in Indonesia and is not required to establish a PE under the applicable laws and regulations.

Ireland's annual budget statement was announced by the Minister of Finance on October 11 2016. The minister confirmed Ireland's commitment to the 12.5% corporation tax rate (a statement which has become a staple in recent budgets) and also confirmed that "nobody is asking for it to be changed".