Sponsored

The 2017 Tax Act added new Section 864(c)(8) on the sale of a partnership interest. The provisions introduce rules that were disputed in Grecian Magnesite v Commissioner.

During 2017 and 2018 the Mexican Stock Exchange witnessed the placement of securities issued by the first two Mexican special purpose acquisition companies (SPACs). Alberto Alvarez and Moisés Gutiérrez of Chevez, Ruiz, Zamarripa y Cia., address some aspects of the operation of said companies, as well as the tax implications that could arise for investors as a result of participating in a Mexican SPAC.

Rachit Agarwal and Jian-Cheng Ku of DLA Piper discuss the transfer pricing (TP) aspects of a business restructuring within a multinational enterprise (MNE) group, through reference to a recent high-stakes Dutch court case. The case highlights the importance of TP documentation as evidence in tax litigation and in conducting an appropriate TP valuation.

Without much fanfare, a tax reform in Chile in December 2017 broadened the rules on the parties considered related for transfer pricing purposes, write Roberto Carlos Rivas and Gregorio Martínez of PwC.

The Irish Revenue Commissioners (Revenue) were successful in arguing before the Appeal Commissioners that no general trading deduction should be available for excess foreign tax incurred on royalties where an Irish tax credit was claimed for part of the foreign tax withheld. The decision is being appealed to the High Court.

A decision rendered by the Superior Court of Justice in favour of the taxpayers determines the concept of inputs for calculating and booking PIS and Cofins credits.

The New Zealand government has released proposals that would require certain foreign sellers, online marketplaces and re-deliverers of goods to register for, collect and return GST on items delivered to a New Zealand address, if the value of the goods is NZ$400 or less, from October 1 2019, write Brendan Brown and Matt Woolley of Russell McVeagh.

The long awaited Announcement 9 has been released by the State Administration of Taxation of China (SAT). Effective from April 1 2018, Announcement 9 replaces Circular 601 and Announcement 30, both of which are key circulars setting out the rules for foreign investors claiming tax treaty benefits on their Chinese-sourced dividends, interest and royalties (passive income).

On March 21 2018, the Swiss Federal Council sent to the Swiss Parliament the dispatch on the draft legislation for the so-called Swiss Tax Reform Proposal 17.