March 2018

Main

No room for doubt: the ‘race to the bottom’ is on

Limited tax perks for MNEs in India’s last budget before 2019 elections

US tax reform: The tax competition risks to the Netherlands and EU

UK considers closer links between employment and tax rules

The EU’s digital tax framework threatened by conflicting political agendas

Singapore budget delivers on GST expectations

Going for gold in transactional tax

The Brockman brief: Fast-track approvals

Tax talent: The world's best transactional firms 2018

Could lower tax demands be the answer to cutting disputes?

Bitcoin and other cryptocurrencies in tax

Making Tax Digital – confusion on the digital journey

US tax reform: GILTI uncertainties

Albania: Albania approves changes to accounting standards; introduces IFRS 15

Australia: Treaty benefits, DPT, MAAL and BEPS MLI

Brazil: Conversion into law of amendments to the oil and gas tax framework

Bulgaria: Changes in the Bulgarian Value Added Tax Act effective as of 2018

Canada: Application and interpretation of the principal purpose test

China: Tax treaty relief clarifications issued

Croatia: Double tax treaty between Croatia and Kosovo enters into force

Cyprus: Cyprus amends VAT; imposes 19% on sale of building land and leasing

Georgia: Georgia updates tax legislation

Germany: Lower tax court rules on direct shareholding requirement under EU PSD

Greece: Clarifications pending on the use of foreign terminal losses

Hong Kong: Hong Kong’s latest tax updates

India: Indian budget 2018-19; Recent rulings on the India-Mauritius treaty

Indonesia: Income tax facility in the industrial sector and draft of regulations on e-commerce tax

Ireland: Closing of the consultation on Ireland’s corporation tax code

Italy: Italian tax police, transfer pricing and business restructuring: still hot topics meriting inspection

Mexico: Lack of business purpose as factor in determining sham transactions

Poland: The CIT-8 return involving new transfer pricing obligations

Portugal: Personal income tax on cryptocurrencies: is the recent ruling a final take?

Serbia narrows down list of services subject to withholding tax

South Africa: CBC reporting in South Africa – new guidelines and practical challenges

South Korea: New rights for taxpayers subjected to a dawn raid

Spain: How should irrevocable trusts be treated for Spanish tax purposes? Quick review of the Spanish tax agency approach

Switzerland: Beware of equity incentive reporting obligations in Switzerland

US Outbound: BEAT to hit inbound taxpayers hard

US Outbound: New LB&I directives both change and clarify IRS transfer pricing procedures

Tax Relief

US tax reform casts an uncertain shadow over M&A

BEPS and US tax reform stall M&A across Asia-Pacific

EMEA's transactional tax market strong despite headwinds

Turkey: Restrictions on foreign currency loans

International updates - March 2018

International Correspondents

Features

New Analysis

Tax Relief

Special Features

Editorial

Sponsored

Sponsored

Sponsored by Hager & Partners

Italy: Italian tax police, transfer pricing and business restructuring: still hot topics meriting inspection

Ten years after the Circular Letter n 1/2008 was issued, on December 1 2017 the Italian tax police (Guardia di finanza) released the updated version of its operational manual for tackling tax evasion and fraud (i.e. Circular n 1/2018). This new document includes – as in the past – a section dedicated to transfer pricing (volume III, part V).

Barbara Scampuddu, February 27 2018
Sponsored by MDDP

Poland: The CIT-8 return involving new transfer pricing obligations

New regulations in the field of transfer pricing documentation came into force in Poland on January 1 2018.

Magdalena Marciniak, February 27 2018
Sponsored by Garrigues Portugal

Portugal: Personal income tax on cryptocurrencies: is the recent ruling a final take?

The taxation of income had been unclear since the recent boom in cryptocurrency trading. The new ruling has come to the delight of tax authorities.

Tiago Cassiano Neves, February 27 2018

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