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

Topics

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Direct Tax

ryan london zoo initiative .jpeg

A taxing week: Ryan’s day at the zoo was more than animalistic self-promotion

CSR initiatives can sometimes venture into virtue signalling, but Ryan’s tax literacy event for schoolchildren was a genuine and necessary endeavour

Tom Baker, May 01 2026

Direct Tax

Grant Thornton.jpg

This week in tax: Grant Thornton extends consolidation drive to Australia

Grant Thornton advanced plans to integrate its Australian firm into its US arm, as tax developments spanned law firm hires, aviation levies and digital services taxes

Tom Baker, May 01 2026

Transfer Pricing

Africa

TP audits are moving upstream, but can African authorities keep pace?

A new focus on early intervention and increased AI use is transforming how tax authorities are approaching TP audits, though capacity-constrained jurisdictions risk falling behind

Akashni Ashok Latchanna, April 30 2026

Direct Tax

AI in Tax Forum 2026.JPG

French tax authority leads way in AI adoption

The French administration has used AI to detect undeclared swimming pools and verandas but always includes a human in the loop, the AI in Tax Forum heard

Ed Conlon, April 29 2026

Direct Tax

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HMRC invites taxpayers to stress-test pillar two filings in ‘private beta’

The UK tax authority’s deputy director of large business also reassured taxpayers that HMRC will not ‘nitpick’ returns

Tom Baker, April 28 2026

Direct Tax

David Beringer, Sucafina, ITR P2 Forum 2026.JPG

Pillar two a ‘box-ticking’ exercise, admits MNE tax head

Sucafina’s tax chief was speaking at the ITR Pillar 2 Forum in London alongside experts from HMRC and other organisations

Ed Conlon, April 28 2026

Direct Tax

India Supreme Court

Tiger Global ruling in India: scope, limits and risks

India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist

Ravish Bhatt, April 28 2026

Direct Tax

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Unity Advisory appoints AI chief as firm hits 100 employees

The UK-based big four spin-off firm has hired Marc Lien, who declared that most AI in professional services today is ‘cosmetic’

Sam Sholli, April 27 2026

Direct Tax

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

A taxing week: Brazil’s pillar two carve-out request prolongs a death by a thousand cuts

Projected revenue losses and exemption requests are harming the project’s capability and viability

Sam Sholli, April 24 2026

Indirect Tax

Prison

This week in tax: HMRC jails payroll fraudsters for 22 years

HMRC secured lengthy prison sentences in a major payroll VAT fraud case, while law firms announced tax promotions and hires

Tom Baker, April 24 2026