International updates - June 2017

June 01 2017

The latest international updates from our correspondents around the world.

Brazil: Tax authorities issue guidance on the treatment of software as a service

Canada: Broadening the de facto control test could impact cross-border transactions

Chile: Concept of beneficiary of a double tax treaty

China: First tax case decision by Chinese Supreme Court

Germany: Finance Ministry issues guidance on the use of a brand name within a multinational group

Greece: Administrative guidelines published on tax benefits of cross-border restructurings

India: Important Supreme Court decisions on tax

Indonesia: Will the amendments to the Income Tax Law simplify the rules?

Ireland: Ireland’s cooperative compliance framework

Italy: New revision of the Italian Transfer pricing provisions on arm’s length principle

Malta: Incentives for Malta’s capital markets

New Zealand: Courts consider challenge to information requests issued at request of foreign tax authority

Norway: Proposed interest limitation rules may impact inbound investments

Poland: The benefits of operating in a special economic zone

Romania: Tax Incentives for companies performing research and development activities

Russia: Bilateral APAs with Russia offer new opportunities

South Africa: SARS confirms zero dividends tax rate in Swedish-South Africa DTA

Spain: Would EU law preclude Spanish inheritance and gift tax legislation in relation to cases involving parties resident in third states?

Switzerland: The impact of currency fluctuations on the CbCR threshold

Turkey: New tax amnesty to be introduced

US Inbound: New IRS APA report shows significant decrease in APA requests

Topics

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More from across our site

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Why in-house tax teams should do their own PR

Heads of tax need to push their teams forward as strategic business advisers to add value across the organisation, says Sandy Markwick

Sandy Markwick, April 25 2025

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This week in tax: Elon Musk and Treasury secretary clash over IRS leadership

Scott Bessent reportedly felt undermined by Musk naming Gary Shapley as acting IRS commissioner; in other news, Baker Tilly will combine with a top 15 US firm

Tom Baker, April 25 2025

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India investment

India’s record APAs a win for government efficiency: experts

The promise of nine years’ tax certainty and a ‘rational and pragmatic’ government process makes APAs a no-brainer, Indian tax advisers tell ITR

Tom Baker, April 24 2025

Transfer Pricing

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Fixing Italy’s approach to taxing digital business

Despite garnering significant revenues from multinationals, Italy’s digital services tax presents pressing double taxation issues, say Stefano Simontacchi and Francesco Saverio Scandone of BonelliErede

Stefano Simontacchi , April 23 2025

Direct Tax

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Asian clients unimpressed with firms’ team depth, exclusive data reveals

ITR’s research shows that in-house tax counsel in Asia also feel underserved by their advisers’ international networks

Tom Baker, April 22 2025

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World Tax and ITR Awards: how to write a winning submission

World Tax global head of research Jon Moore tells ITR how his team spots standout submissions, and gives early statistical insights into this year’s entries

Tom Baker, April 21 2025

Direct Tax

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Tax advisory regulation would be slashed under Aussie conservative government

Australia’s conservative opposition will repeal controversial tax agent reporting rules if elected in the country’s May general election

Tom Ravlic, April 18 2025

Direct Tax

Internal Revenue Serice Sign

This week in tax: Gary Shapley tipped to become acting IRS commissioner

Shapley would be the fourth person to hold the job this year; in other news, UK tax advisory firm MHA raised fewer funds than expected from its London IPO

Tom Baker, April 17 2025

Transfer Pricing

‘General pause’ on pillar one in many countries: BDO tax leader

The US needs to be involved in pillar one for there to be more international acceptance of the project, Michael Masciangelo says

Sam Sholli, April 17 2025

Direct Tax

EY’s regulatory troubles continue as FRC launches Post Office probe

The UK regulator is investigating EY’s auditing of the national postal service as it relates to the high-profile Horizon scandal, which saw hundreds wrongfully convicted

Tom Baker, April 16 2025