International updates - May 2018

Australia: Integrity measures impacting stapled structures, managed investment trusts and foreign investors

Canada: Tracking arrangement proposals: the foreign affiliate rules and segregated portfolio companies

Chile: Cryptocurrencies in Chile

China: Measures to liberalise financial sector and reduce VAT

Croatia: Tax relief: city of Vukovar and assisted areas

Cyprus: Cyprus updates DTAs and protocols and signs new ones

Hong Kong: China clarifies beneficial ownership requirements – how this impacts Hong Kong

India: Supreme Court: dominant purpose of investment is irrelevant in determining whether expenditure is ‘in relation to’ exempt dividend income

Indonesia: Updates on corporate income tax allowance and AEOI

Italy: New definition of permanent establishment aligned with BEPS Action 7

Luxembourg: Impact of MLI’s principal purpose test on private equity sector

New Zealand: Court of Appeal considers double tax relief article in DTA with China

Poland: Digitalisation of VAT settlements

Serbia: Serbia joins Global Forum on Transparency and Exchange of Information

South Africa: Budget 2018: tax and exchange control proposals

Spain: The Spanish Supreme Court ends discrimination against non-resident heirs outside the EU

Switzerland: Swiss Tax Reform Proposal 17: Swiss Federal Council submits dispatch to Swiss Parliament

US Inbound: Sale of partnership interest