International updates - June 2017

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International updates - June 2017

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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

more across site & bottom lb ros

More from across our site

One expert argues the ERS would be unlikely to improve taxpayers’ experience unless it comes with additional funding to hire more agents and staff
From pillar two and amount B to Apple’s headline EU Commission dispute, Martin Bonner and Yiwen Ping of Kreston Global argue that 2024’s key TP developments will inform 2025
Holland & Knight, Nelson Mullins and McCarter & English made the joint-most tax partner hires in the US last year, according to annual ITR Talent Tracker data
Despite a three-year-high in tax revenues generated from settling TP cases, HMRC reported a sharp fall in resolved MAP disputes
Inflexion’s proposed minority stake in Baker Tilly Netherlands could propel the firm in the Dutch market, CEO Ronald Hoeksel tells ITR
While the US’s dramatic exit from the OECD’s global tax deal naturally grabbed headlines, Trump’s premeditated move shouldn’t detract from pillar two’s lofty ambitions
The ‘big four’ firm’s audit of gambling company Entain is under the spotlight; in other news, Ireland shrugs off Trump’s rejection of pillar two
Mid-market European private equity house Inflexion, which also backs law firm DWF, has agreed to acquire a minority stake in the Dutch tax advisory firm
Donald Trump’s inauguration, pillar two, APAs and TP were all up for discussion as ITR spoke to Baker McKenzie’s two newly minted US partners
In-house teams that want a balance of internal control and external expertise for pillar two should seriously consider co-sourcing models, Russell Gammon of Tax Systems argues
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