World Tax Advisor – Connecting you globally
World Tax Advisor is a bulletin of international tax developments written by professionals of the member firms of Deloitte. It focuses on analyses of cross-border tax developments that reflect the dynamic business environment faced by multinationals. We are pleased to share with you an update of recent tax treaty developments.
Australia’s tax authorities target cross-border profit-shifting arrangements
The tax authorities have identified issues of concern, as a result of a review of certain arrangements used by multinationals and large companies operating in Australia.
Brazil: Ultimate beneficiary disclosure required
Certain domestic and foreign legal entities are required to disclose to the tax authorities the complete chain of ownership up to the ultimate beneficiaries, as well as the legal representatives of owners.
France: Temporary additional depreciation mechanism to be extended
The parliament is reviewing a bill that would extend the temporary additional depreciation mechanism for another year and would allow more assets to benefit from the enhanced deduction.
Hungary: Updated tax audit guidelines released
The tax and customs authority has issued guidelines setting forth items of focus for tax audits in fiscal year 2016, which are intended to reflect trends and business practices that may result in tax risks.
India: Supreme Court clarifies definition of fees for technical services
The Supreme Court has clarified the scope of services that should be deemed to be technical in nature, an area that has been fraught with controversy.
Italy: Changes made to patent box ruling procedure
The tax authorities have issued guidance that revises the procedural rules relating to the application for a tax ruling under the patent box regime introduced in the 2015 stability law.
Puerto Rico: US district court holds AMT provisions unconstitutional
A district court has struck down certain provisions of the alternate minimum tax regime and has prohibited the tax authorities from enforcing the unconstitutional components of the regime.
Taiwan: Focus on e-commerce tax issues to intensify
Changes to the tax treatment of cross-border e-commerce transactions are on the horizon, including revisions to legislation and an increased focus in tax audits.
In brief
News in brief from Belgium, Czech Republic, the EU, France, Luxembourg, New Zealand, the US and Vietnam.
BEPS corner
Updates on developments in the OECD’s Base Erosion and Profit Shifting initiative, including developments from Australia, Denmark, the EU, the OECD, South Africa, Switzerland and Taiwan.
For more information and access to archives, please visit the World Tax Advisor page.
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