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Chile: Entry into force regime for Chile’s General Anti-Avoidance Rule

Astrid Schudeck Jonatan Israel The interpretation of the General Anti-Avoidance Rule (GAAR) by the Chilean tax authority, concerning the entry into force of the provision, has been subject to strong criticism and confusion. This is because of conflicting interpretations of the rules and because the GAAR could apply to transactions performed before the entry into force date of September 30 2015 if the effects of the said transactions are generated afterwards.

July 12 2016

EU: Commission publishes working paper on state aid and tax rulings

Bob van der Made The European Commission (EC)'s Directorate General for Competition has published its working paper on state aid and tax rulings. It provides an overview of DG Competition's preliminary orientations after review of the member states' tax ruling practices.

July 12 2016

Switzerland: Swiss parliament approves Corporate Tax Reform III

Jacques Kistler Rene Zulauf The Swiss parliament approved Corporate Tax Reform III (CTR III) on June 17 2016. The main objectives of the reform are to align Swiss tax law with international standards and to enhance Switzerland's attractiveness as a location for multinational enterprises.

July 12 2016

Tax Relief

We all wish we could magic away our tax bills sometimes We all sometimes wish that we could wave a magic wand and make the tax go away – but Rupert Grint, who stars as Ron Weasley in the Harry Potter films, might have more reason to do so than most after taking the UK revenue authority, HMRC, to court in a £1 million ($1.3 million) dispute.

July 12 2016

US Inbound: Medtronic wins US transfer pricing case

Jim Fuller David Forst Medtronic is a recent and important US transfer pricing case. The case involved, among other things, the royalty rate payable by a Puerto Rican affiliate of the US taxpayer that produced medical device products.

July 12 2016

Brexit: Navigating the tax minefield

The UK’s vote to leave the European Union has spurred multinationals in the UK, Europe, North America and Asia to reconsider their operations in Britain. Anjana Haines looks at the potential tax implications of a post-Brexit UK and its relationship with the EU.

Anjana Haines, July 12 2016

India has begun renegotiation of several tax treaties

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India: Renegotiation of tax treaties by India

With a view to examining consequential issues arising out of amendments to the India-Mauritius tax treaty and related issues, a Working Group has been set up.

Hariharan Gangadharan, July 12 2016

Brexit: Withholding taxes ahead for businesses

Multinational enterprises are considering whether to move their UK headquarters to one of the remaining 27 EU nations, as withholding taxes could be charged once EU laws cease to apply.

Anjana Haines, July 12 2016

Brexit: Implications for indirect taxation and cross-border trade

The UK’s VAT rules could change after an EU exit, meaning charges for imports and exports between the UK and EU member states. Preferential customs and duty rates in the single market could also end upon leaving the EU Customs Union.

Anjana Haines, July 12 2016

Brexit: What next for UK businesses?

The UK’s vote to leave the EU is expected to trigger changes to tax legislation, potentially driving up the compliance and administrative burden for businesses. So what should multinationals be considering?

Anjana Haines, July 12 2016

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