October 2018

Main

Luxembourg’s new VAT grouping regime has plenty of downsides

Market insight: EY’s takeover of Riverview Law

Americas Tax Awards 2018

US tax reform 2.0 advances at frantic pace

Tax disputes put $75 billion of Fortune 500 profits in the firing line

Wayfair and the Dunkin’ Donuts philosophy

Why Grant Thornton and BDO want audit reform

Brazil: Amendments to protocol to Brazil and Argentina tax treaty enacted

It’s always an eventful month

Chief strategic officer: A new world

Vodafone’s Glenn Price talks tax and risk

Tax planning amid political instabilities and tax grabs

Special features - October 2018

Albania: Albania changes income tax law, introduces incentives for agro-tourism

Australia: MLI, hybrid mismatch, MITs and staple structures, cross-border financing and reduced company tax rate

Bulgaria: Bulgaria allows electronic storage of employment documents

Canada: ‘Partnerships’ in Canada

Chile aiming to join era of indirect tax on digital services

China: Tax support for innovation and new regulatory framework for e-commerce

Croatia: Tax incentives for research and development in Croatia

Egypt: Central Bank of Egypt defends bank accounts secrecy

European Union: Outgoing Juncker commission’s plans for tax until November 2019

Georgia: Georgia concludes double taxation treaty with Saudi Arabia

Germany: Using statistical analysis to improve TNMM

Hong Kong: Recent accounting changes in Hong Kong

Indian tax treaty benefits available without providing a tax residency certificate

Indonesia: Commencement of AEOI and priority target for tax audit

Italy: Intercompany charges, cost inherence and deductibility

Luxembourg: VAT committee publishes guidelines on VAT treatment of cash pooling

Montenegro: Citizenship by investment in Montenegro

Netherlands: Dutch participation exemption and the write-down of receivables

New Zealand: New Zealand issues draft guidance on BEPS-related reforms

Poland: Income tax on buildings: Amendments

Portugal: Liquidation proceeds sourced in Spain and exemption method for non-habitual tax residents

Tax audits – a disruptive routine for every taxpayer

Serbia: Serbia amends VAT Law, extending eligibility for VAT refund to foreign companies

South African dividend stripping rules: Impact on liquidations and cross-border share buybacks

Switzerland: EU DAC6 mandatory disclosure rules – why should Swiss intermediaries care?

Turkey: Recent tax developments

US Inbound: Altera decision reversal withdrawn

US Outbound: New updates to CAP focus on transfer pricing issue resolution

The GP Surgery: Certainty, secrecy and DAC16

Tax Relief

Robert McGuinness joins Marks Paneth in New Jersey

Euromoney Asia Women in Business Law Awards 2018: winners announced

International updates - October 2018

No. 1: David Bradbury & Giorgia Maffini

No. 2: Pierre Moscovici

No. 3: Digital tax – the outliers

No. 4: Artificial intelligence and the robot tax

No. 5: The US judicial system

No. 6: Brexit

No. 7: Donald Trump

No. 8: Pascal Saint-Amans and Achim Pross

No. 10: Margaret Hodge and Andrew Mitchell

No. 9: Monica Bhatia

International Correspondents

Features

New Analysis

Tax Relief

Special Features

Editorial

Sponsored

Sponsored

Sponsored by EY Romania

Tax audits – a disruptive routine for every taxpayer

In recent years, due to the fairly low percentage of tax collection, the Romanian tax authorities (RTA) have increased pressure on revenue collection by various means.

October 15, 2018
Sponsored by PwC Brazil

Brazil: Amendments to protocol to Brazil and Argentina tax treaty enacted

On 28 August 2018, Decree 9.482 was published, enacting amendments to the protocol to the convention between Brazil and Argentina.

Fernando Giacobbo, October 15, 2018
Sponsored by DLA Piper Australia

Australia: MLI, hybrid mismatch, MITs and staple structures, cross-border financing and reduced company tax rate

In recent weeks, we have seen important Australian tax developments that are relevant to multinationals and inbound investments. With many initiatives taking effect as early as January 1 2019, multinationals should consider the potential impact on their inbound and outbound Australian investments.

October 15, 2018

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