NEWS: INTERNATIONAL TAX REVIEW
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   NEWS: INTERNATIONAL TAX REVIEW
International Tax Review
Dec 10, 2018

Indian GAAR disputes to continue but there is hope, say tax directors
Tax departments must be extra-vigilant to avoid costly litigation resulting from India's recurrent and creative use the general anti-avoidance rule, say tax directors - but even strong documentation may not be enough.

International Tax Review
Dec 10, 2018

Traditional retailers welcome German marketplace VAT compliance law
German retailers are pleased with a new VAT compliance law which will put additional obligations on online platforms selling goods, which they say will help level the playing field. But major platforms like Amazon, eBay and Etsy face a compliance headache.

International Tax Review
Dec 06, 2018

Daniel Hawthorne promoted to partner at Dechert in London
The longtime associate at the firm will be a partner from January 1 2019.

International Tax Review
Dec 06, 2018

Digital tax ball ‘back in the OECD court'
Member states have killed off the EU's digital services tax (DST) proposal, but companies fear this will make unilateral action more likely.

International Tax Review
Dec 06, 2018

Pinheiro Neto elects two new tax partners
Andrea Mascitto and Ana Carolina Carpinetti have been promoted to partners in the tax practice of the Brazilian firm.

International Tax Review
Dec 06, 2018

DSR Tax Claims adds a tax compliance officer
Callum Foster has joined the compliance team at DSR Tax Claims in Nottingham with a background in financial administration and account management.

International Tax Review
Dec 05, 2018

Global Tax 20 2018
International Tax Review's Global Tax 20 highlights the most influential people, events, countries and companies which have had an impact on the global tax landscape during the past year. The top 10 are out now, and the full list will be released later this month.

International Tax Review
Dec 05, 2018

Banks and tax authorities outline how blockchain can cut costs
Tax chiefs at banks are say they will implement blockchain technologies to cut costs and improve regulatory compliance. However, it may take government regulation to persuade businesses to implement the direct ledger technology.

International Tax Review
Dec 03, 2018

Businesses brace for controversial Polish mandatory disclosure rules
Tax heads and advisors are in the dark about how Poland's mandatory disclosure rules (MDR) will work. Poland's measures go beyond the EU Directive and could set a standard among EU nations implementing MDR.

International Tax Review
Nov 30, 2018

Facebook, Google and Kering Group questioned by EU MEPs
Facebook and Google emphasised the importance of international consensus on changes to the international tax system to tax the digital economy and the scope of value creation during an EU Parliament committee hearing.

International Tax Review
Nov 30, 2018

Evolution and adaptation with Kering Group
Kering's Group Tax Director Sophie Maddaloni explains how the group's corporate structure has enabled it to transform from a timber and construction specialist, to a distribution business, to the luxury goods group it is today.

International Tax Review
Nov 30, 2018

EU Parliament calls for cum-ex schemes inquiry and tougher rules
The cum-ex and cum-cum schemes that defrauded EU financial hubs of billions of euros continue to exist in other forms across Europe. An investigations unit and stricter laws could be introduced to tackle the fraud following a parliamentary vote.

International Tax Review
Nov 29, 2018

Brazil's Viseu Advogados hires new partner
Luis Augusto Da Silva Gomes has joined the São Paolo office of Viseu Advogados as partner and head of tax litigation.

International Tax Review
Nov 28, 2018

Mauritius remains a favourite among treaty shoppers
Treaty shopping is still a common practice among taxpayers when investing in Africa, and Mauritius remains one of the best jurisdictions for minimising tax liabilities.

International Tax Review
Nov 28, 2018

Bennett Jones adds five to its tax team
The Canadian firm Bennett Jones has appointed Ed Kroft, Jehad Haymour, and Deborah Toaze as partners and Sophie Virji and Eric Brown as associates to the Vancouver, Calgary and Toronto offices.

International Tax Review
Nov 28, 2018

Businesses call for wider Japan tax reform after consumption tax rise
Japanese businesses are nervous that public pressure could again postpone an increase to the consumption tax rate, further delaying the overhaul of the tax system that they want.

International Tax Review
Nov 26, 2018

BDO and Moore Stephens set for UK merger
BDO and Moore Stephens are in advanced merger discussions to join forces in spring 2019, in a move that would create the UK's fifth-largest audit firm, behind the Big 4 accountancy firms.

International Tax Review
Nov 26, 2018

How tax departments deal with uncertainty
Tax directors explain how they are trying to manage the political and legislative uncertainty around the world that is constantly changing the way their teams have to operate.

International Tax Review
Nov 23, 2018

More taxes ahead as Canada announces deficit-financed tax proposals
Canadian Finance Minister Bill Morneau announced several tax measures in the Fall Economic Statement to persuade companies to invest long-term, but the incentives raise the country's deficit and risk more taxes in the near future.

International Tax Review
Nov 23, 2018

Canada announces deficit-financed tax incentives that risk future tax hikes
Canadian Finance Minister Bill Morneau announced several tax measures in the Fall Economic Statement to persuade companies to invest long-term, but the incentives raise the country's deficit and risk more taxes in the future.

International Tax Review
Nov 23, 2018

Countries disagree on advantages of MLI ‘synthesised texts'
Jurisdictions are beginning to create ‘synthesised texts' to help taxpayers understand how the OECD's multilateral instrument (MLI) interacts with bilateral double tax treaties, but some believe they do not offer the legal clarity taxpayers seek and risk future disputes.

International Tax Review
Nov 23, 2018

Weil, Gotschal & Manges appoints new tax partner and counsel
Ludger Kempf and Aron Joy have been appointed to partner in the Frankfurt tax practice and counsel in the London tax team of Weil, Gotschal & Manges, respectively.

International Tax Review
Nov 22, 2018

Luxembourg treaty exemption for gains from immovable property
The Tax Court of Canada recently found in Alta Energy Luxembourg v the Queen, 2018 TCC 152 (August 22 2018) that a non-resident was entitled to exemption from Canadian tax under the Canada-Luxembourg Income Tax Convention (Lux Treaty) on capital gains realised from the sale of shares of a private Canadian oil and gas company.

International Tax Review
Nov 20, 2018

VAT implementation in Bahrain should be ‘pretty easy'
Multinationals believe preparation for VAT in Bahrain should be easier than in Saudi Arabia and the United Arab Emirates (UAE), despite the fact that Bahrain has not yet released its full VAT legislation.

International Tax Review
Nov 20, 2018

Brazil clarifies tax treatment of international charter leasing payments
Brazilian tax authorities have provided guidance on the application of the reduced 0% income withholding tax rate on international charter leasing payments.

International Tax Review
Nov 20, 2018

Brazil clarifies the tax treatment of international charter leasing payments
Brazilian tax authorities have provided guidance on the application of the reduced 0% income withholding tax rate on international charter leasing payments.

International Tax Review
Nov 19, 2018

Proposed US regulations expand scope on tax-free foreign income
Proposed regulations for section 956 of the Internal Revenue Code could offer US multinationals the ability to use up to 100% of CFC assets as collateral for loans and other transactions, but there is uncertainty over their scope.

International Tax Review
Nov 19, 2018

US proposed regulations expand scope on tax-free foreign income
Proposed regulations for section 956 of the Internal Revenue Code could offer US multinationals the ability to use up to 100% of CFC assets as collateral for loans and other transactions, but there is uncertainty over its scope.

International Tax Review
Nov 16, 2018

Nigeria's Tunde Fowler: Digital tax solution must work for everyone
Nigerian revenue authority leader Tunde Fowler has emphasised the importance of coming up with a digital taxation solution that works for both developing and developed countries, as well as the business community.

International Tax Review
Nov 16, 2018

Kathleen Russ elected as first woman senior partner of Travers Smith
Kathleen Russ will succeed Chris Hale as senior partner of Travers Smith, effective July 1 2019.

International Tax Review
Nov 15, 2018

J5 identifies ‘dozens' of tax evasion enablers from online hunt
Data scientists and criminal investigators from the Joint Chiefs of Global Tax Enforcement initiative, or J5, discovered "multiple" new tax evasion enablers across Australia, Canada, the Netherlands, UK and US in a 24-hour pursuit, they told International Tax Review.

International Tax Review
Nov 14, 2018

Ex-EY specialist joins KPMG as a tax director
Jennifer Cooper has joined KPMG's international tax team in London.

International Tax Review
Nov 14, 2018

KPMG director joins Ayming
Mark Smith has joined consultancy firm Ayming from KPMG to become a partner in its innovation incentives practice in the UK.

International Tax Review
Nov 13, 2018

Taxand hires René Matteotti as new counsel in Switzerland
René Matteotti, a lawyer and University of Zurich professor, will move to Tax Partner, Taxand Switzerland.

International Tax Review
Nov 13, 2018

Tax heads relieved as EU's digital tax hits a roadblock
Tax directors across the European and the US are glad to hear the EU's digital tax proposals have been delayed because they "create chaos", contain too many uncertainties and can be applied in "all sorts of ways".

International Tax Review
Nov 13, 2018

KPMG promotes Manal Corwin to head of Washington tax practice
Manal Corwin has been appointed to principal-in-charge of KPMG's Washington national tax (WNT) practice in the US.

International Tax Review
Nov 13, 2018

Lack of international tax consensus on cryptocurrency
The definition of cryptocurrency and how it should be taxed varies widely among different tax authorities around the world.

International Tax Review
Nov 12, 2018

US Ways & Means counsel joins Miller & Chevalier
Miller & Chevalier has hired Loren Ponds, former tax counsel to the US House Committee on Ways and Means.

International Tax Review
Nov 12, 2018

The displeasures of the greatest tax dispute in Brazil
Taxpayers are still waiting for clarity in one of Brazil's most important tax disputes, which cost the federal government around BRL 250 billion ($68 billion) when it was concluded in March 2017.

International Tax Review
Nov 12, 2018

Malaysia budget proposals may encourage aggressive tax tactics
In-house executives predict tax planning will become more aggressive in Malaysia following changes announced in the annual budget on how they can use tax losses.

International Tax Review
Nov 09, 2018

Spanish digital services tax targets big tech companies
Spain's digital services tax (DST) is slated to enter into force in January 2019, despite the criticism and concerns of multinational technology companies, write Rafael Calvo and Juan Camilo Sánchez of Garrigues, Taxand Spain.

International Tax Review
Nov 08, 2018

Paradise Papers fail to expedite tax changes a year after scandal
A year after the release of the Paradise Papers, some politicians, tax justice campaigners, and legal professionals believe too little has changed. Actions beyond the BEPS project may be necessary, says one MP.

International Tax Review
Nov 08, 2018

Brazil: Personal use of off-the-shelf software not subject to withholding tax
The federal Brazilian tax authority (RFB) has confirmed that off-the-shelf software acquired for personal use should not be subject to withholding tax.

International Tax Review
Nov 07, 2018

US tax director shares his approach to success in global tax
The tax director of a fast-growing American online business using data to deliver a global digital service shares his secrets of tax success with International Tax Review.

International Tax Review
Nov 07, 2018

US mid-term elections spell gridlock for taxpayers
A divided Congress following the mid-term elections means US businesses can expect the Tax Cuts and Jobs Act (TCJA) to stay, but the possibility of a technical corrections bill is dead in the water.

International Tax Review
Nov 07, 2018

DAC 6 reporting requirements pose numerous compliance problems
The taxpayer challenges arising from the EU's directive on mandatory disclosures for intermediaries (DAC 6) are seemingly countless, writes Christian Kaeser, global head of taxes at Siemens, and Mark Orlic and Arne Schnitger of PwC.

International Tax Review
Nov 06, 2018

What is happening with the tax treatment of foreign insurance undertakings?
Public information contained in the official register of the Spanish insurance supervisor states that there are 77 insurance and reinsurance undertakings (referred to as insurers henceforth) operating in Spain under the EU freedom of establishment regime.

International Tax Review
Nov 05, 2018

Marc Sanders moves from Taxand Netherlands to EY
Marc Sanders and three members of his team have moved to EY in Amsterdam from Taxand Netherlands as of November 1.

International Tax Review
Nov 05, 2018

China: More tax measures to cope with the challenging global economic environment
In recent months, the trade issues between China and the US have continued to escalate. So far, the US has imposed 10% tariffs on $250 billion out of the more than $500 billion of China exports to the US, and China has responded with tariffs on $110 billion out of $130 billion US exports to China.

International Tax Review
Nov 02, 2018

KPMG South Africa looks to rebuild trust with clients
KPMG South Africa plans to restore its reputation with a new leader following the scandal over its role in auditing the Gupta-owned businesses, but rival firms are already poaching their clients who no longer trust the firm.

International Tax Review
Nov 02, 2018

UK MPs prepared to impose public registers on crown dependencies
British MPs may be preparing to impose public registers on the UK's crown dependencies if places like Jersey don't voluntarily open their books and expose the real owners of major companies.

International Tax Review
Nov 02, 2018

Latham & Watkins promotes two to partner
Bryant Lee and Bora Bozkurt have been promoted to tax partners at Latham & Watkins.

International Tax Review
Nov 02, 2018

Brazil: Payments for trademark use to French entity subject to withholding tax
The Federal Brazilian tax authority (RFB) has confirmed that payments for the right to use trademarks and know-how to a French entity should be subject to income withholding tax and CIDE.

International Tax Review
Nov 01, 2018

Hong Kong: Chief executive's 2018 policy address sets out tax plan
Chief Executive Carrie Lam Cheng Yuet-ngor delivered her second policy address on October 10 2018, which sets out the Hong Kong government's policies over the coming years.

International Tax Review
Oct 31, 2018

HMRC appoints new general counsel
Alan Evans is the new general counsel and solicitor for the UK tax authority, HM Revenue and Customs.

International Tax Review
Oct 31, 2018

UK's safe harbour in proposed DST offers little comfort to taxpayers
A tax director at a FTSE 100 company has said they are puzzled over how the safe harbour in the UK's proposed digital services tax (DST) will exempt lossmaking companies.

International Tax Review
Oct 31, 2018

Brazil: Tax authorities say French not-for-profit organisations subject to tax
Brazilian tax authorities have said that no relief should be granted for withholding tax on payment to foreign not-for-profit organisations under the Brazil-France double tax agreement (DTA).

International Tax Review
Oct 31, 2018

Philip Morris International eyes the tax benefits of e-cigarettes
Philip Morris International (PMI) is expanding its line of alternatives to cigarettes, gaining the benefit of a lower tax rate and making less harmful products cheaper, the company has told International Tax Review.

International Tax Review
Oct 30, 2018

Garrigues appoints four new tax partners
Garrigues, Taxand Spain has appointed four individuals to partners.

International Tax Review
Oct 30, 2018

Restriction of VAT deduction for transactions settled using the reverse charge mechanism in Poland
Lidia Adamek-Baczynska and Olga Palczewska of WTS&SAJA dissect the differences between Polish and EU VAT law, the opportunities and difficulties these differences present,, and relevant case law.

International Tax Review
Oct 29, 2018

UK budget: Digital services tax set for 2020
Chancellor Philip Hammond has committed the UK to a digital services tax (DST) in the absence of an OECD agreement, turning the rhetoric about an ‘Amazon tax' into reality.

International Tax Review
Oct 29, 2018

Valentiam Group launches in transfer pricing in the US
A group of tax professionals, mainly from US transfer pricing firm Economics Partners, have formed a new firm, Valentiam Group.

International Tax Review
Oct 26, 2018

Natural gas industry stands to gain from a carbon tax
British multinational BP explains why it is working with Shell and ExxonMobil to lobby for a carbon tax in the US that could offer them an advantage over the coal industry as the market moves towards renewables.

International Tax Review
Oct 26, 2018

Robert McGuinness joins Marks Paneth in New Jersey
Accounting, tax and advisory firm, Marks Paneth has appointed Robert McGuinness as a director in the firm's commercial business group.

International Tax Review
Oct 25, 2018

Market insight: Merging two tax departments
Bryan Cave Leighton Paisner's Global Head of Tax Elizabeth Bradley and US Tax Partner Philip Wright tell International Tax Review about how they merged the two old firms' tax teams strategically by finding a compatible culture and work policy.

International Tax Review
Oct 25, 2018

Interview: Philip Morris International weighs up its excise challenges
Huub Savelkouls, vice president of social and economic affairs at Philip Morris International, talks to ITR about dealing with high excise rates and the tax implications of replacing cigarettes with vapour products.

International Tax Review
Oct 25, 2018

Italy's Studio Biscozzi Nobili joins WTS network
Milan-based tax law firm Studio Biscozzi Nobili (SBN) has joined the WTS network as a member firm.

International Tax Review
Oct 24, 2018

Brazil's tax reform will implement significant changes
Although the Brazilian tax system is complex and costly, there is a light at the end of the tunnel with ongoing debates to overhaul the tax system and the presidential elections.

International Tax Review
Oct 24, 2018

Interview: Philip Morris weighs up its excise challenges
Huub Savelkouls, vice president of social and economic affairs at Philip Morris, talks to ITR about dealing with high excise rates and the tax advantages of replacing cigarettes with vapour products.

International Tax Review
Oct 24, 2018

Deloitte Middle East appoints Jason Riche to lead tax technology services
Jason Riche has left Deloitte Canada to join the Middle East practice as partner and the tax technology leader.

International Tax Review
Oct 23, 2018

Italy: new law decree restricts relocation outside Italy where beneficial regimes are granted
Law Decree 87 dated July 12 2018 (also known as the 'dignity decree' or 'decreto dignità') was approved by the Italian government in early July 2018 and finally converted into Law 96/2018 by Parliament. It entered into force on August 12 2018.

International Tax Review
Oct 23, 2018

Survey: Do you know the best tax transactional and tax advisory firms?
Companies can vote now for the best tax firms for transactional and advisory services. We only take answers from clients because they alone can determine the true value of the advice they have received from a firm.

International Tax Review
Oct 22, 2018

Tax directors must rise to the challenge in Africa
Tax has certainly become more challenging in Africa, but understanding the current situation requires context. Taxation is only part of a bigger picture, which must also include the broader opportunities and risks involved in operating on the continent.

International Tax Review
Oct 22, 2018

‘Nothing is off the table' in UK budget
Brexit negotiations will likely take precedence over all other factors when UK Chancellor Philip Hammond presents his autumn budget, a tax director at a major energy company told ITR, but the situation is very open-ended for tax policy.

International Tax Review
Oct 18, 2018

The tax competition debate part three: What would a regulatory framework look like?
Richard Murphy and Arthur Laffer exchange views on whether regulating tax competition could work, and how it would affect countries.

International Tax Review
Oct 18, 2018

The tax debate part three: What would a regulatory framework look like?
Tax justice campaigner Richard Murphy and renowned economist Arthur Laffer whether regulating tax competition could work, and how it would affect countries.

International Tax Review
Oct 18, 2018

RSM expands network to Cyprus
RSM has added a new member firm in Cyprus, RTBS.

International Tax Review
Oct 17, 2018

The tax competition debate part two: Is it possible to regulate?
Renowned economist Arthur Laffer and leading tax activist Richard Murphy debate whether it is possible - or desirable - to regulate tax competition between different jurisdictions.

International Tax Review
Oct 17, 2018

The ITR European Tax Awards 2019: Submit now
Companies, firms and individuals can now enter for the International Tax Review European Tax Awards 2019.

International Tax Review
Oct 17, 2018

Andersen Global continues South American expansion
Paraguay law firm BKM Berkemeyer has signed a collaboration agreement with Andersen Global.

International Tax Review
Oct 16, 2018

The tax competition debate part one: Is it harmful?
Tax justice campaigner Richard Murphy and renowned economist Arthur Laffer go head to head to debate one of the defining tax issues of the post-financial crisis world: tax competition.

International Tax Review
Oct 16, 2018

Mexico court rules against taxpayer in transfer pricing case
Mexico's First Circuit Court has recently ruled against a taxpayer in a case involving two transfer pricing adjustments that will make it tougher for companies to comply with their domestic tax obligations on time.

International Tax Review
Oct 16, 2018

Mike Minihan becomes partner at BX3 Capital
Mike Minihan has come out of retirement to join BX3 Capital, a business advisory firm for the blockchain and cryptocurrency space, as a partner.

International Tax Review
Oct 15, 2018

Luxembourg's new VAT grouping regime has plenty of downsides


International Tax Review
Oct 15, 2018

UK tax laws after Brexit
On June 26 2018 the European Union (Withdrawal) Act 2018 (EUWA) received Royal Assent and therefore became an Act of the British Parliament (law).

International Tax Review
Oct 15, 2018

David Lewis and Mark Prater join PwC US
PwC has added David Lewis and Mark Prater to its US tax practice.

International Tax Review
Oct 14, 2018

Asia Tax Awards 2019: Enter now
Companies, firms and individuals working in jurisdictions across the Asia Pacific region must enter now to compete for the Asia Tax Awards 2019.

International Tax Review
Oct 14, 2018

The ITR Asia Tax Awards 2019: Enter now
Companies, firms and individuals working in jurisdictions across the Asia Pacific region can enter now to compete for the Asia Tax Awards 2019.

International Tax Review
Oct 12, 2018

Where are Mexico's special economic zones?
During 2017 and 2018, Mexico's President Enrique Peña Nieto issued diverse decrees designating the following Mexican regions (shown in the map below) as special economic zones (SEZs).

International Tax Review
Oct 12, 2018

Mazars promotes two to tax partners
Ronald Plat and Alexander Rasink have become partners at the Amsterdam and Rotterdam offices, respectively, of Mazars.

International Tax Review
Oct 11, 2018

Tax competition is stabilising, says Saint-Amans
Pascal Saint-Amans, director of the Centre for Tax Policy and Administration at the OECD, says that headline corporate tax rates are stabilising following US tax reform - with some exceptions.

International Tax Review
Oct 11, 2018

Thierry Charon joins Loyens & Loeff's new executive board
Thierry Charon, co-head of Loyens & Loeff's VAT, customs and international trade practice group in the Benelux has been appointed as a member of the firm's executive board.

International Tax Review
Oct 11, 2018

UK opens investigation into audit market
The UK's competition watchdog has launched an investigation into the accounting industry over claims that the dominance of the Big 4 has led to a decline in audit quality.

International Tax Review
Oct 10, 2018

Ireland's budget 2019 introduces a new exit tax
Ireland's budget 2019 has introduced an exit tax earlier than anticipated, but it could be welcome news for US multinationals torn between the benefits of Ireland and US tax reform.

International Tax Review
Oct 10, 2018

Haciendo bien la digitalización con Intercorp Retail
El director de contabilidad corporativa de Intercorp Retail comparte su experiencia de cómo el minorista multiformato trabajó con las autoridades fiscales para establecer el mejor modelo de prácticas para la facturación electrónica en Perú.

International Tax Review
Oct 10, 2018

Keith Thomas joins Alvarez & Marsal Taxand
Alvarez & Marsal Taxand (A&M Taxand) has appointed Keith Thomas as managing director of the tax advisory practice in its London office.

International Tax Review
Oct 09, 2018

Doing digitisation right with Intercorp Retail
Intercorp Retail's corporate accounting director shares his experience of how the multi-format retailer worked with the tax authorities to establish a best-practice model for electronic invoicing (e-invoicing) in Peru.

International Tax Review
Oct 08, 2018

Businesses ill-prepared for UK's Making Tax Digital after Brexit
UK taxpayers are still behind schedule on prepping for the rollout of Making Tax Digital (MTD) and the end of traditional VAT returns on April 1 2019, which happens just days after Brexit, according to a recent poll.

International Tax Review
Oct 05, 2018

Tax authorities going digital is not helping corporations to comply
Tax administrations need to harmonise their tax filing and data requirements to give taxpayers a better chance of complying, say in-house advisers and tech aficionados.

International Tax Review
Oct 05, 2018

US has to engage in global digital tax debate
Failing to participate in the global digital tax debate would be a mistake the US would regret, say a senior tax executive and former Microsoft tax counsel.

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