NEWS: INTERNATIONAL TAX REVIEW
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   NEWS: INTERNATIONAL TAX REVIEW
International Tax Review
Jul 16, 2018

Domino's Pizza case ‘encouraging' for MNEs expanding into India
Foreign multinationals can expand their brand presence in India through a franchise agreement without suffering a higher tax burden imposed on permanent establishments (PE) following the Domino's Pizza case.

International Tax Review
Jul 13, 2018

Philippe Freund joins Fieldfisher in London
Philippe Freund has joined Fieldfisher's London office as a partner in the tax disputes and investigations team.

International Tax Review
Jul 13, 2018

Malaysia High Court backs safeguard duties for the steel sector
Countries are going to great lengths to protect their respective steel industries. S Saravana Kumar and Jason Tan from Lee Hishammuddin Allen & Gledhill discuss their landmark court win to rejuvenate the Malaysian steel industry.

International Tax Review
Jul 12, 2018

Google: Multilateral framework necessary to tax the digital economy
Google's Head of Trade and Economic Affairs Andrew Ure has stressed the importance of consensus on how to tax the digital economy, saying a multilateral agreement is the only real solution.

International Tax Review
Jul 12, 2018

Digital tax: An ‘arms race' between the EC and the OECD
The search for a long-term digital tax solution has been compared to an arms race, with the EC vying for the lead role over the OECD, while the UN places its bets.

International Tax Review
Jul 12, 2018

Retroactivity threat looms for companies after Wayfair case
Some states are pushing the boundaries of the US Wayfair judgment by applying their sales tax rules retroactively, putting them on a direct collision course with taxpayers.

International Tax Review
Jul 10, 2018

The ‘Harry Kane theory of value' and the flaws in the EU's digital tax plans
Value creation is where the problems begin with digital tax. How can you decide where the value is created by England's World Cup strip? Michael Devereux explores whether it is Russia, England or Bangladesh.

International Tax Review
Jul 09, 2018

Tax reforms likely as Lopez Obrador wins Mexican elections
Mexico's transition into a new government is set to begin in December, and a series of reforms are expected to commence based on Lopez Obrador's campaign commitments.

International Tax Review
Jul 09, 2018

Wayfair: Foreign-based companies at risk of US state taxes
Foreign companies need to examine the potential consequences of the US Wayfair case as states consider hunting for more tax dollars abroad, say tax advisers.

International Tax Review
Jul 09, 2018

Mexico ratifies Framework Agreement of the Pacific Alliance
The agreement, approved by Mexico, will harmonise the applicable tax treatment on certain interest income and capital gains to avoid double taxation across Chile, Colombia, Mexico and Peru.

International Tax Review
Jul 06, 2018

Tax authorities join forces to tackle cyber tax crimes
The tax authorities in Australia, Canada, the Netherlands, the UK and the US have turned their attention to cyber criminals and enablers of transnational tax crime.

International Tax Review
Jul 06, 2018

One in 10 multinationals to restructure ‘soon' due to BEPS and ATAD
The BEPS Project and the EU Anti-Tax Avoidance Directive (ATAD) are forcing some companies into restructuring, according to a new survey. But many are still waiting for more clarity before they decide their next move.

International Tax Review
Jul 06, 2018

Investment firms eye the rewards of US tax reform
US tax reform has led global investment firm KKR to convert to a corporate structure in anticipation of higher share prices. Asset management companies (AMCs) are keeping a close eye on this bold decision.

International Tax Review
Jul 05, 2018

Charles Russell Speechlys adds two partners in Luxembourg
Charles Russell Speechlys has hired Jean-Baptiste Beauvoir-Planson as a corporate law partner, and promoted Yacine Diallo to partner, in its Luxembourg office.

International Tax Review
Jul 05, 2018

Brazil's latest tax legislation updates for the oil and gas industry
The oil and gas industry in Brazil has historically been seeking specific tax rules for its specific activities. This landscape is finally changing, but not all the legislative amendments are positive for the sector.

International Tax Review
Jul 04, 2018

The Cayman Islands seeks UK talks over public registers
The Cayman Islands has requested talks with the UK over its constitutional status in response to the plan to introduce public beneficial ownership registers to overseas territories.

International Tax Review
Jul 03, 2018

Stroock hires special counsel in New York
Private wealth lawyer Shifra Herzberg has joined Stroock as special counsel in its New York office.

International Tax Review
Jul 03, 2018

What Brexit means for UK holding companies
While the UK government struggles to find an exit deal with the EU, International Tax Review's Leading Women in Tax Forum take charge of how Brexit may affect UK holding companies.

International Tax Review
Jul 02, 2018

Duff & Phelps adds new European head of transfer pricing in London
Duff and Phelps has added Ted Keen as managing director and head of the firm's European Transfer Pricing practice in London.

International Tax Review
Jul 02, 2018

Brazilian Federal Government questionably reduces REINTEGRA tax benefit for exporters
The Brazilian Federal Government has determined, effective immediately, that the rates for calculating REINTEGRA deemed credits must be reduced from 2% to 0.1%, without respecting the grace period for the rule to become effective.

International Tax Review
Jun 29, 2018

Morrison & Foerster expands New York tax practice with new partner
Anthony Carbone has joined Morrison & Foerster's New York office, bringing with him a wealth of experience on business restructuring, insolvency, private equity, M&A and fund formation practices.

International Tax Review
Jun 29, 2018

EC's state aid decision in Engie takes aim at hybrid loans
The state aid decision opens the door for the European Commission (EC) to set a precedent on several points of law, including hybrid loans between EU and non-EU group companies.

International Tax Review
Jun 27, 2018

How Apple and McDonald's restructured their European tax affairs post-state aid
Apple has publicly said that it reorganised its tax arrangements after the EU's state aid investigation. Yet a new study claims Apple may have paid as little as 0.7% in taxes on its European sales since then.

International Tax Review
Jun 26, 2018

Cooley hires new tax partner
Alexander Lee has joined as a tax partner in Cooley's Los Angeles office.

International Tax Review
Jun 25, 2018

Australia's new B2B landscape and GST registration options for non-Australian entities
As the Australian Goods and Services Tax (GST) system undergoes more changes, Raoul D'Cruz, Jim Koutsokostas and Michael Parker of Hall & Wilcox provide a recap on how the GST system has been simplified for non-residents over the past few years and outline the key registration systems that may be available to non-residents.

International Tax Review
Jun 22, 2018

Germany and France forge EU corporate tax pact
Germany and France have agreed to move the European Union towards a common consolidated corporate tax base (CCCTB), which would transform tax in the bloc. But the measure is not popular everywhere in the EU.

International Tax Review
Jun 22, 2018

Deloitte announces senior promotions in New Zealand
Deloitte has promoted two new partners and three new directors: Bart De Gouw, Hadleigh Brock, Bronwyn Baird, Jamie Hall and Muhammad Cajee.

International Tax Review
Jun 21, 2018

BREAKING: Tax chaos looms as US Supreme Court rules in favour of South Dakota in Wayfair case
The Supreme Court has thrown the US tax system into chaos by ruling in favour of South Dakota in the Wayfair case. Multinationals around the world face huge tax exposure and smaller businesses which sell online could face ruin.

International Tax Review
Jun 21, 2018

Alvarez & Marsal Taxand adds new senior directors in Denver and New York
Alvarez & Marsal Taxand, an affiliate of the global firm Alvarez & Marsal, has announced it will be hiring Jon de Jong in Denver and Louis Mancini in New York, bolstering the firm's global tax practice.

International Tax Review
Jun 21, 2018

Tax chaos looms as US Supreme Court rules in favour of South Dakota in Wayfair case
The Supreme Court has thrown the US tax system into chaos by ruling in favour of South Dakota in the Wayfair case. Multinationals around the world face huge tax exposure and smaller businesses which sell online could face ruin.

International Tax Review
Jun 20, 2018

Avalara begins trading on the NYSE
Tax software company Avalara began trading on the New York Stock Exchange (NYSE) on June 15.

International Tax Review
Jun 20, 2018

Avalara goes public on the NYSE
Tax software company Avalara began trading on the New York Stock Exchange (NYSE) on June 15.

International Tax Review
Jun 20, 2018

Inside the legal challenge to the UK's public ownership registers
The UK government may be on a collision course with the British Virgin Islands (BVI) and the Cayman Islands over plans to introduce public registers of beneficial ownership across UK overseas territories.

International Tax Review
Jun 19, 2018

Andersen Global bolsters Brazilian tax practice
Andersen Global continues its growth in Latin America with the addition of Lotti e Araujo, a Brazilian corporate law firm with particular expertise in tax litigation, as well as the civil and labour sectors.

International Tax Review
Jun 18, 2018

How multinationals beat a US city council
Amazon and Starbucks won their battle with Seattle City Council to prevent a new tax on big employers coming into effect. But what does this say about the relationship between taxpayers and local government?

International Tax Review
Jun 15, 2018

Alvarez & Marsal Taxand adds two senior directors in Denver and New York
Jon de Jong and Louis Mancini have joined Alvarez & Marsal Taxand, an affiliate of the global firm Alvarez & Marsal, as senior directors.

International Tax Review
Jun 15, 2018

Jonathan Ivinson joins King & Spalding in Switzerland
King & Spalding has added a new partner to its Swiss tax practice in the form of Jonathan Ivinson, who joins the firm's Geneva office from Akin Gump Strauss Hauer & Feld.

International Tax Review
Jun 15, 2018

Could tackling the tax compliance burden shrink the UK tax gap?
The UK's tax gap has remained steady, but it is tax evasion and an increasing compliance burden that is concerning the tax community.

International Tax Review
Jun 14, 2018

Wall Street waits for US tax reform 2.0
Wall Street banks are delaying tax restructuring while they wait for the US Congress to present a new tax bill before the 2018 mid-term elections.

International Tax Review
Jun 13, 2018

US Supreme Court decision in Wayfair sales tax case imminent
The US Supreme Court's decision in the seismic South Dakota v Wayfair case, which concerns state sales tax, may be released as soon as tomorrow (June 14). It could leave companies around the world facing retroactive exposure in the billions of dollars.

International Tax Review
Jun 13, 2018

What can Malaysia's new SST learn from GST?
Malaysia will bring in a sales and services tax (SST) in September 2018 to replace the unpopular goods and services tax (GST). Tax practitioners expect a "hybrid" SST regime that retains some GST features.

International Tax Review
Jun 13, 2018

Dentons hires new senior counsel
Dentons has hired Siamak Mostafavi as a senior counsel in its Paris office.

International Tax Review
Jun 12, 2018

European Court's Hornbach-Baumarkt ruling gives clarity on arm's-length principle
Taxpayers will be able to argue more effectively against transfer pricing readjustments following a key ruling on the arm's-length principle in the Hornbach-Baumarkt case.

International Tax Review
Jun 11, 2018

Will Cejudo joins Dechert in Washington DC
Dechert has added Will Cejudo as a partner in the firm's international and domestic tax practice group. He will focus on tax matters relating to structured finance transactions.

International Tax Review
Jun 08, 2018

Euromoney LMG Americas Women in Business Law Awards 2018: winners announced
The best women lawyers in the Americas gathered at the JW Marriott Essex House hotel in New York last night to celebrate the achievements of women across firms, practice areas and jurisdictions.

International Tax Review
Jun 08, 2018

Bishop Fleming promotes a trio of directors to partner
The accounting firm Bishop Fleming has promoted Isobel Savage, Nathan Coughlin and John Talbot to the partnership to help meet increasing demand for its services.

International Tax Review
Jun 07, 2018

Matheson makes Barry McGettrick partner in its Dublin tax practice
Irish law firm Matheson has promoted Barry McGettrick to partner in its Dublin tax practice.

International Tax Review
Jun 07, 2018

South African businesses review contracts after Barclays Africa drops KPMG
Barclays Africa Group Limited (BAGL) has dropped KPMG as its auditors because of its ties with the Gupta family and the related corruption scandal. Other companies fearing reputational damage are also reviewing their relationships with some large accounting firms in South Africa.

International Tax Review
Jun 07, 2018

Top HMRC lawyer leaves for Oxford University
Gill Aitken, top adviser and head of the solicitor's office and legal services at the HMRC, is moving to a new role as registrar at the University of Oxford.

International Tax Review
Jun 07, 2018

GST on low-value goods in Australia: How to be compliant
International Tax Review analyses the different ways Amazon and eBay are adapting to be compliant with Australian GST laws once low-value goods are no longer exempt from July 1.

International Tax Review
Jun 07, 2018

How Amazon and eBay will comply with Australia's GST changes
International Tax Review analyses the different ways Amazon and eBay are adapting to be compliant with Australian GST laws once low-value goods are no longer exempt from July 1.

International Tax Review
Jun 06, 2018

WTS Global and LATAXNET sign cooperation agreement
WTS Global and LATAXNET have entered into an exclusive cooperation agreement.

International Tax Review
Jun 05, 2018

Carbon taxation revenue rose by 50% in 2017 - or did it?
Global revenue from carbon pricing rose by 50% in 2017 compared to 2016, says a new report from the World Bank. While companies can expect green taxes to keep rising, this statistic doesn't quite tell the whole story.

International Tax Review
Jun 04, 2018

DLA Piper hires new partner in Brussels office
DLA Piper has hired Philippe Hinnekens as a partner in its Brussels office.

International Tax Review
Jun 01, 2018

The UK still can't answer its Brexit customs question
The UK government's preferred post-Brexit customs arrangements are deeply unpopular with most of the UK's exporting and importing business community. New proposals for a 10-mile ‘buffer zone' in Northern Ireland are likely to face heavy political opposition, sending the debate back to square one.

International Tax Review
Jun 01, 2018

James Jackson lands DIGI role at TIGTA's Office of Investigations
James Jackson has become deputy inspector general for investigations (DIGI) at the U.S. Treasury Inspector General for Tax Administration (TIGTA) following his service role as ‘acting' DIGI since January 1 2018.

International Tax Review
Jun 01, 2018

Is GDPR putting companies off the UK's anti-VAT fraud scheme?
While Amazon, eBay and Fruugo have signed up to HMRC's new disclosure scheme for VAT fraud, major online marketplaces like Etsy and Alibaba have not. Advisers suspect GDPR may be partly to blame.

International Tax Review
May 31, 2018

KPMG adds to US tax practice
KPMG has made seven new hires in its US tax practice.

International Tax Review
May 30, 2018

David Wheat joins Kirkland & Ellis's tax team in Houston
David Wheat has joined Kirkland & Ellis's tax practice group as a partner in the firm's Houston office.

International Tax Review
May 30, 2018

Why McDonald's has restructured its tax affairs
Facing fresh claims of tax avoidance, McDonald's has defended its tax structure, telling International Tax Review why it moved its intellectual property (IP) from Luxembourg to the UK.

International Tax Review
May 29, 2018

Bracewell expands New York team
Bracewell has added three new partners and an associate to its litigation team in New York.

International Tax Review
May 29, 2018

Impartiality: Condition of validity of the judgments rendered by the CARF
After launching the Zelotes operation, the discussion on the restructuring of the Administrative Tax Appeals Council (CARF) was intensified. In relation to this, there are at least six bills pending before the Brazilian Congress, write João Marcos Colussi and Gabriel Mendes Gonçalves Issa of Mattos Filho.

International Tax Review
May 29, 2018

Why tax avoidance by multinationals and Illicit financial flows are the same thing
Logan Wort, executive secretary of the African Tax Administration Forum (ATAF), argues that harmful tax practices can be eliminated by addressing this specific component of illicit financial flows.

International Tax Review
May 25, 2018

BEPS Action 12 rules on mandatory disclosure will limit options for German MNEs, say advisers
Germany is moving forward with plans to institute mandatory disclosure rules for national tax planning strategies that lack a cross-border component, and could adopt a draft proposal as soon as next month.

International Tax Review
May 25, 2018

SNC-Lavalin defends its tax affairs after being named in West Africa leaks
Canadian engineering company SNC-Lavalin has defended its use of a Mauritian company, telling International Tax Review that it structures its business in a tax-efficient manner that's compliant with the law.

International Tax Review
May 25, 2018

Garrigues hires Javier de la Vega as partner
Garrigues has hired Javier de la Vega as a partner in Peru as it looks to expand its Latin American tax offering. De la Vega moves from PwC.

International Tax Review
May 24, 2018

Cyrus Daftary joins KPMG in the US
Cyrus Daftary has joined KPMG's financial services global banking practice as principal of the group's information reporting and withholding tax practice.

International Tax Review
May 24, 2018

Big data will make or break use of the cloud for tax reporting
Implementing digital tax compliance tools is inevitable for corporations as real-time tax reporting gains momentum. But using cloud reporting or may expose some tax teams to data risks.

International Tax Review
May 24, 2018

Malaysia scrapping GST is bad news for tax departments, as are potential replacements
Companies must prepare for another rise in tax compliance costs with Malaysia poised to abolish the goods and services tax (GST) after just three years. Analysts warn that tax directors may have to also reassess their accounting, IT and pricing strategies.

International Tax Review
May 23, 2018

Andersen Tax continues expansion in Latin America with new Mexico office
Andersen Tax & Legal has announced a new presence in the Mexican city of Monterrey.

International Tax Review
May 23, 2018

Brazilian Superior Court of Justice defines concept of inputs for PIS and COFINS purposes
A decision rendered by the Superior Court of Justice in favour of the taxpayers determines the concept of inputs for calculating and booking PIS and Cofins credits.

International Tax Review
May 22, 2018

Eversheds hires Paul Beausang as head of real estate tax
Paul Beausang, former head of real estate at Morgan Lewis & Bockius, is now partner and head of real estate tax at Eversheds Sutherland in the UK.

International Tax Review
May 22, 2018

MNEs get easy ride under US repatriation and GILTI regimes as US expats pick up the bill
Although the 2017 US Tax Cuts and Job Act (TCJA) aimed to cut taxes for all Americans, individual US shareholders of controlled foreign corporations (CFCs) living outside the US (expats) are being discriminated against under the repatriation and GILTI tax regimes. Monte Silver of Silver & Co in Israel, explains why the likes of Google and Apple are getting a good deal.

International Tax Review
May 21, 2018

MNEs prepare for BEPS bill after New Zealand budget's limited tax proposals
New Zealand Finance Minister Grant Robertson refrained from proposing many corporate tax proposals in his 2018 budget, leaving the tough measures against MNEs to the BEPS bill.

International Tax Review
May 17, 2018

European Tax Awards 2018: Winners announced
Europe's leading tax firms dominated this year's European Tax Awards through innovation and outstanding tax controversy management.

International Tax Review
May 17, 2018

New Zealand to require foreign sellers of low-value goods to register for GST
The New Zealand government has released proposals that would require certain foreign sellers, online marketplaces and re-deliverers of goods to register for, collect and return GST on items delivered to a New Zealand address, if the value of the goods is NZ$400 or less, from October 1 2019.

International Tax Review
May 17, 2018

Travers Smith promotes Madeline Gowlett to partner
Madeline Gowlett is one of eight lawyers to be promoted by Travers Smith to its partnership, with effect from July 1 2018.

International Tax Review
May 17, 2018

New slate of executive officers elected for IFA USA
A new slate of executive officers were elected for the US branch of the International Fiscal Association (IFA USA) at its February 23 annual meeting in Houston, the IFA announced on May 7.

International Tax Review
May 17, 2018

Netflix ‘disappointed' with ECJ country of origin state aid ruling
The European General Court (EGC) ruled on May 16 that Netflix and other companies cannot overturn the European Commission's (EC's) approval of a film fund levy in Germany.

International Tax Review
May 17, 2018

Netflix ‘disappointed' with EU country of origin state aid ruling
The European General Court (EGC) ruled on May 16 that Netflix and other companies cannot overturn the European Commission's (EC's) approval of a film fund levy in Germany.

International Tax Review
May 16, 2018

Arendt & Medernach adds four senior associates
Alexandra Clouté, Philipp Jost, Claire Schmitt, and Benjamin Tempelaere have been promoted to senior associate in the tax law practice at Arendt & Medernach in Luxembourg.

International Tax Review
May 15, 2018

PLMJ makes João Velez de Lima a partner
Portuguese law firm PLMJ Advogados has promoted four lawyers to partner, including João Velez de Lima, who works in the firm's Oporto office tax team.

International Tax Review
May 15, 2018

Updated: A brief timeline on the developments of the LuxLeaks case
ITR breaks down the developments that led to the conviction, and subsequent court cases, of former PwC employees Antoine Deltour and Raphaël Halet, who exposed more than 300 multinational enterprises benefiting from sweetheart tax deals with the Luxembourg authorities to avoid taxes in Europe.

International Tax Review
May 15, 2018

Mattos Filho hires two tax partners
Mattos Filho, Veiga Filho, Marrey Jr & Quiroga Advogados has hired two new tax partners in its Rio de Janeiro and Sao Paulo offices.

International Tax Review
May 15, 2018

LuxLeaks verdict sets ‘strong precedent', says acquitted ex-PwC whistleblower Antoine Deltour
Luxembourg's Court of Appeal has cleared whistleblower Antoine Deltour of stealing PwC documents in the LuxLeaks scandal. Deltour told International Tax Review the ruling sets a strong precedent for tax justice.

International Tax Review
May 14, 2018

Amendments to Uruguay's Free Zones Act
Uruguay's parliament has amended several provisions of the Free Zones Act, impacting tax benefits. Guzmán Ramírez of Bergstein Abogados provides a summary of the main amendments introduced in such an act.

International Tax Review
May 11, 2018

Simmons & Simmons hires Marco Palanca in Italy
Marco Palanca has left Clifford Chance to lead the tax department at Simmons & Simmons in Italy.

International Tax Review
May 11, 2018

Danny Beeton joins Arendt & Medernach
Transfer pricing expert Danny Beeton has joined Arendt & Medernach in Luxembourg as of counsel.

International Tax Review
May 11, 2018

MNEs hit by Australia's R&D tax proposals in 2018 budget
Companies may begin to look elsewhere to invest in research and development after Australia's Treasurer Scott Morrison said he will be cracking down on the use of R&D tax incentives.

International Tax Review
May 11, 2018

How the ATAD will drive up financing costs
Concern is growing among Sweden's financial services sector about how the EU Anti-Tax Avoidance Directive (ATAD) will affect financing costs, but a tax director at a Swedish private equity fund warns that these issues also apply to many more industries.

International Tax Review
May 10, 2018

Companies see no gain in splitting Big 4 tax and audit functions
UK proposals to separate tax and audit functions within the Big 4 accounting firms will not make a difference to the market or the way businesses choose their advisers, a tax director at a major fintech company has told International Tax Review.

International Tax Review
May 08, 2018

Vertex promotes Bernadette Pinamont
Vertex has promoted Bernadette Pinamont to vice president of tax research.

International Tax Review
May 08, 2018

Vertex promotes Bernadette Pinamont to vice president of tax research
Vertex promotes Bernadette Pinamont to vice president of tax research.

International Tax Review
May 07, 2018

Andersen Tax consolidates Uruguay presence
Andersen Global has consolidated its presence in Uruguay by adding Fischer & Schickendantz as a full member firm.

International Tax Review
May 04, 2018

Coca-Cola optimistic ahead of IRS dispute ruling
As the trial nears its end, Coca-Cola is confident of its chances of winning the high-stakes case against the IRS, according to the company's 10k filing. The IRS is demanding $3.3 billion in back taxes, plus interest.

International Tax Review
May 04, 2018

Andersen Global expands to Peru
Andersen Tax has signed a collaborative agreement with Picón & Asociados as part of its expansion across Latin America.

International Tax Review
May 03, 2018

Asia Tax Awards 2018: Winners announced
Firms, individuals and companies across the Asia-Pacific region shared prizes at the Asia Tax Awards in Singapore on May 3 2018.

International Tax Review
May 03, 2018

Alvarez & Marsal hires new managing directors in the US
Alvarez & Marsal Taxand has hired Jay Helverson and Rick Gardner, and several professionals from their team, from WTS US.

International Tax Review
May 03, 2018

Alvarez & Marsal appoints two senior directors
Alvarez & Marsal (A&M) Taxand UK has appointed Louise Jenkins and Andrew Ponting, formerly of FTI Consulting, as senior directors in its European tax practice.

International Tax Review
May 02, 2018

Higher fixed establishment risk in Poland
Recent tax rulings and judgments of administrative courts in Poland have provided new insight into the concept of fixed establishment in Poland. However, the tax authorities and courts often employ a taxpayer-unfriendly approach.

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