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  • Rafael Calvo Elisa San Salvador On March 16 2016 the Supreme Court handed down a relevant judgement on the tax treatment for Spanish tax purposes of the 'juros sobre o capital próprio' (JSCP) distributed by Brazilian affiliates to their Spanish parent companies.
  • Sandra Benedetto Ignacio Nunez As the framework for the global exchange of information regarding investments abroad is being moulded, Chile – as the only South American member of the OECD – has been highly committed to applying such principles and, in order to promote tax assistance and transparency, has signed international conventions and reformed domestic legislation at a legal and administrative level.
  • The timing of the ‘Panama Papers’ could enable the EC to force through CbCR The European Commission (EC), emboldened by the public outcry at the 'Panama Papers' leak, is refusing to back down on its plans for public country-by-country reporting (CbCR).
  • Election day – November 8 – may still be some way off, but the buzz around the battle for the presidency is already at peak levels, largely driven by the polarising Donald Trump and his drive for the Republican presidential nomination. But while his hairdo continues to dominate the front pages, how would a Trump-inspired tax reform be received on the business pages? Amelia Schwanke analyses where each of the front-runners for the White House stand on corporate tax.
  • John Leopardi Alexandra Carbone In March, the Federal Court of Appeal (FCA) overturned the Tax Court of Canada (TCC) judgment in The TDL Group Co. (TDL). The FCA allowed the interest deduction claimed by TDL on funds borrowed from its direct US parent, Delcan, that were used to purchase additional common shares of its wholly-owned subsidiary, Tim Donut US Limited (Tim US). A summary of the TCC decision was published on March 30 2015.
  • Christiana Nicolaou If you already own an intellectual property (IP) box company in Cyprus, or if you are considering such a move, recent international developments at G20, OECD and EU level, along with the Cyprus Ministry of Finance's [MoF] December 30 2015 announcement, require your special attention.
  • Khoonming Ho Lewis Lu On March 24 2016, China's Ministry of Finance and the State Administration of Taxation jointly issued Circular Cai Shui [2016] 36 (Circular 36) which contains the Value Added Tax (VAT) rates and rules applicable to the expansion of China's VAT system to several key sectors such as real estate and construction, financial services, and lifestyle services, which take effect from May 1 2016.
  • Alvaro Pereira Ruben Gottberg In November 2011, the Brazilian Government signed the Convention on Mutual Administrative Assistance in Tax Matters (CMAAT), which establishes rules for sharing tax information between the G20 countries. In general terms, the CMAAT provides for all possible forms of administrative cooperation between the parties in the assessment and collection of taxes, in particular with a view to combating tax avoidance and evasion, while considering high standards of confidentiality and protection of personal data. The CMAAT was approved by Brazil's Senate on April 14 2016. It should enter into force three months after the deposit of the ratification instrument.
  • The Kotak Securities case has clarified the definition of ‘technical services’ The Indian Supreme Court (SC) has ruled that transaction charges paid for online trading facility though the stock market do not constitute 'fees for technical services' (FTS) in a recent tax case involving Kotak Securities.
  • Life is what happens to you while you're busy making other plans, or so sang John Lennon in 1980. For a bohemian, free-spirited musician, this may be true. But ask any taxpayer and they will tell you that failing to make plans will invariably lead to non-compliance and the associated enemies of any company's bottom-line: fines, penalties and reputational damage to the corporate brand.