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In December 2017, Russia passed into law the three-tiered approach for transfer pricing (TP) documentation in accordance with OECD BEPS Action Plan 13.

In line with its pledge to boost Hong Kong's competitiveness and comply with its international obligations, the Hong Kong government has recently introduced two tax reforms.

The federal Brazilian tax authorities (RFB) published a declaratory act regarding the withholding tax on payments abroad for a license to distribute or commercialise software.

In the final days of 2017, the Chinese authorities set out a series of new incentives and improved tax treatments with a view to fostering both greater inbound and outbound investment in 2018. The Chinese Finance Minister, Mr Xiao Jie, also set out his plan of broader reforms for the medium term.

Renata Correia Cubas, partner at Mattos Filho, writes about the landmark progress made so far on tackling the tax wars between Brazilian states on state VAT and what you can expect from 2018.

A thrilling year-end in the cryptocurrency space, where most virtual currencies raised their value in three digit percentages in a matter of months, is ushering in a new wave of investors looking for high-risk/high-return opportunities. This makes the issuance of guidance on the taxation of transactions executed with digital currencies a pressing matter.

The SAT ruling now has expanded the situations where the 4.9% withholding tax rate is not applicable to include interest derived from certificates, loans and other financial transactions.

India has seen several important decisions on the tax front take place in 2017.

The OECD guidelines, which were updated in July 2017 to incorporate Action Plan 13 of the BEPS project, provide a minimum requirement of maintaining a three-tiered documentation system.