Proposed changes to the Income Tax Act, contained in the 2019 draft Taxation Laws Amendment Bill, were released for comment by the National Treasury on July 21 2019.

Multinationals across all sectors should be ready as fundamental changes to the international taxation system make their way into reality. Alison Lobb, Robert Stack and Paul Riley introduce this special report.

The OECD’s work around the digitalisation of the economy is proceeding at a rapid pace and many multinational enterprises may be surprised at the scope of changes to the international tax framework. These changes could impact all larger multinationals, not just those that consider themselves part of the digital economy.

Endy Arya Yoga and Nanda Atsatalada of GNV Consulting summarise legislative updates concerning corporate income tax reduction facilities, bad debt expense deductions from gross income, and implementation of the Core Tax Administration System

Karanjot Singh Khurana, Devashish Jain, and Kanika Jain of Lakshmikumaran & Sridharan examine a ruling requiring multinational enterprises to pay taxes on profits attributed to their permanent establishment in India, despite global losses

Jun Au of DLA Piper Australia summarises the Australian Taxation Office’s newly set out considerations in deciding whether to examine a debt restructure and the key tax rules concerning corporate collective investment vehicles

Claudia Sofianu and Dan Răut of EY Romania discuss the growing challenges of cross-border teleworking, highlighting the complexities of taxation rights and the need for clearer and more unified EU regulations

The interest deduction rules in relation to Dutch real estate companies are set to change. Jian-Cheng Ku and Thijs Haverbeke of DLA Piper Netherlands discuss the update and provide ideas for mitigating any adverse effects

Teresa Teixeira Mota and Francisco Lencastre Torres of Vieira de Almeida & Associados explain how generative AI and enhanced human understanding can help in-scope Portuguese constituent entities manage the complexities of pillar two compliance

Paulo Victor Vieira da Rocha and Murilo Jakuk of VRMA Advogados discuss a recent decision by the Brazilian Supreme Court that ensures proportionality in tax penalties and strengthens legal protections for businesses

Paulo Victor Vieira da Rocha and Murilo Jakuk of VRMA Advogados discuss the recently published Provisional Measure 1262/24 and Normative Instruction 2228/24 as a statement of Brazil's commitment to the OECD's global tax standards

Carlos Jorge Vargas and Rodrigo Gómez Sánchez of Mascareño Vargas – Asesores explore Paraguay’s appeal to international investors and highlight the country’s competitive tax regime as a particularly significant factor in attracting foreign capital

Henriette Fuchs of Yaron-Eldar, Paller, Schwartz & Co in Tel Aviv reports on two substantial new tax benefits designed to stimulate and preserve continued investment in technology companies

Henriette Fuchs of Yaron-Eldar, Paller, Schwartz & Co in Tel Aviv concludes the follow-up article on SAFE investments in Israel, outlining the relative certainty of walking the safe “green path”.

In the first of a two-part article, Henriette Fuchs of Yaron-Eldar, Paller, Schwartz & Co in Tel Aviv reports on Israel tax authorities’ acceptance of the SAFE for investment in innovative and tech companies.

Michael Bernard of Vertex says adapting to the US’s challenging tax regime relies on an understanding of what is known as the nexus principle

With 45 states imposing a sales tax, Michael Bernard of Vertex explains the key points to note for European businesses aiming to broaden their market and capitalise on the e-commerce boom in the US

Mark Martin and Thomas Bettge of KPMG in the US discuss the recent amount B consensus document and the associated compliance challenges

Dinko Dinev and Adam Wojewoda of Deloitte Luxembourg explore AI’s potential to enhance efficiency in transfer pricing but emphasise the irreplaceable value of human expertise in navigating complex regulatory landscapes

Multinational enterprises must include transfer pricing and cost accounting experts in taking an integrated approach to supporting the arm’s-length nature of intragroup service charges, say Enrique Marchesi-Herce, Gilles Andreini, and Serena Picariello of Deloitte Luxembourg

Mark Martin and Thomas Bettge of KPMG in the US discuss the first published statistics on the International Compliance Assurance Programme and their implications for businesses looking to obtain tax certainty