International updates - May 2016

April 29 2016

The latest international updates from our correspondents around the world.

Albania: IMF requests amendments to Albanian property tax

Australia: Australian BEPS update pre-election

Brazil: Brazil’s Senate approves Convention on Mutual Administrative Assistance in Tax Matters

Canada: Federal Court of Appeal agrees with TDL on scope of Canadian interest deductibility purpose test

Chile: Change of scenery: Chilean tax assistance and transparency

China: China’s new VAT rates and rules across all industries

Croatia: Treaty analysis: Croatia-Luxembourg DTA enters into force

Cyprus: Recent developments in Cypriot IP taxation: Are you prepared?

EU: EU Commission proposes public CbCR

Germany: EGC rules German exception to change-in-ownership rule qualifies as unlawful state aid

India: Taxing digital transactions in India

Indonesia: Indonesia targeting cross-border and online transactions

Ireland: New Irish tax appeals system

Italy: Italian Revenue Agency issues guidelines on LBOs

Luxembourg: Luxembourg VAT: CJEU delivers important decision regarding real estate investment funds

Poland: Incoming reporting changes in Poland

Russia: Transfer pricing audits in Russia: Initial results and trends

Serbia: Treaty analysis: Serbia ratifies DTA with South Korea

South Korea: Tax Tribunal rules Korean tax authority had no basis to disregard the existence of domestic holding companies established to facilitate LBO

Spain: Spanish Supreme Court confirms that Brazilian ‘juros sobre o capital próprio’ can benefit from Spanish participation exemption regime

Switzerland: Swiss perspective: Standardised electronic format for the exchange of CbC reports released by the OECD

US Inbound: US proposes new debt-equity regulations regarding interest in a corporation

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Advisers hope Brazil and US reach agreement on Trump tariffs

The threat of 50% tariffs on Brazilian goods coincides with new Brazilian legal powers to adopt retaliatory economic measures, local experts tell ITR

Sam Sholli, July 18 2025

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This week in tax: Germany still ‘committed’ to pillar two despite chancellor’s condemnation

The country’s chancellor appears to have backtracked from previous pillar two scepticism; in other news, Donald Trump threatened Russia with 100% tariffs

Tom Baker, July 18 2025

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OECD unveils pillar two safe harbour for highly taxed MNEs

In its latest G20 update, the OECD also revealed tense discussions with the US where the ‘significant threat’ of Section 899 was highlighted

Tom Baker, July 17 2025

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Too many HMRC compliance investigations last too long, committee warns

The tax agency has increased compliance yield from wealthy individuals but cannot identify how much tax is paid by UK billionaires, the committee also claimed

Sam Sholli, July 17 2025

Transfer Pricing

UK TP proposals could ‘double compliance costs’, tax firm warns

Saffery cautioned that documentation requirements in new government proposals must be limited if medium-sized companies are not exempted from TP

Tom Baker, July 16 2025

Direct Tax

OECD image.jpeg

Pillar two no longer has a future, German chancellor claims

The global minimum tax deal is not viable without US participation, Friedrich Merz has argued

Sam Sholli, July 16 2025

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Pillar two is revising global tax competition with a 15% minimum tax rate

Future of pillar two uncertain after Section 899 withdrawal averts ‘catastrophe’

Section 899 of the ‘one big beautiful’ bill would have spelled disaster for many international investors into the US, but following its shelving, attention turns to the fate of the OECD’s pillars

Ralph Cunningham, July 16 2025

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‘Pro bono is a must’: Amory Heine on giving back

DLA Piper’s co-head of tax for the US and Latin America tells ITR about her fervent belief in equal access to the law, loving yoga, and paternal inspirations

July 15 2025

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‘Huge, complex’ pillar two system encroaches on sovereignty: EY tax leader

Tax expert Craig Hillier agrees with the comparison of pillar two to using a sledgehammer to crack a nut

Sam Sholli, July 14 2025

Direct Tax

London- HM Revenue and Customs building on Whitehall, UK Governm

HMRC believes US companies underpaid £8.8bn in tax: accountancy group

The amount is reported to be up 57% from the £5.6bn that the UK tax agency believes was underpaid in the previous year

Sam Sholli, July 14 2025