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The US tax system is on the brink of change as upcoming discussions centre on tax policy (including regulations related to inversion transactions) that will ultimately reshape the US tax treatment of inter-company financing within MNEs. In the second half of 2016, a stream of new regulations and law changes, both actual and proposed, in and outside of the US, created new issues for inter-group financing by multinationals. Stuart Chessman, director at Vivendi, discusses the salient points.

Companies want tax regimes across the Asia-Pacific region to be more consistent and predictable, but believe they are becoming increasingly complicated in countries such as India and China, according to a recent survey.

In light of the US Tax Court’s decision in Amazon v. Commissioner of Internal Revenue, many important predictions have been made about the impact this case will have on future transfer pricing litigation. However, it is important to look at the valuable lessons that should be learned by practitioners, corporations, attorneys, and tax authorities when documenting intercompany transactions, specifically intangibles. John Wiora, director of operations at ktMINE, investigates.

CMS has appointed eight partners to its tax group in its 2017 round of global promotions.

Sweden plans to introduce new rules on the taxation of commercial real estate that may complicate tax credits for foreign taxpayers and potentially result in double taxation. Richard Hedin Thyr, tax partner, and Hussein Abdali, tax adviser, at Skeppsbron Skatt, Taxand Sweden, analyse what these proposals could mean.

Barbara Scampuddu Gian Luca Nieddu The Italian tax authorities have issued a resolution that should help multinationals selling goods and services into Italy, or using the country for storage or distribution.

Freddy Karyadi Nina Cornelia Santoso In preparation for the first exchange of information (EOI) by September 2018, the Indonesian government has enacted several implementing regulations, despite the ongoing discussions to issue a Government Regulation in Lieu of Law (Peraturan Pemerintah Pengganti Undang-undang, or Perppu) as the legal basis for EOI in Indonesia. The said Perppu is currently being proposed to the President and is expected to be signed in the near future. Upon its enactment, the Perppu shall become effective, despite the initial plan to implement the first EOI by 2018. Subsequently, the Indonesian tax authority may immediately access both foreign or local customer information data from banking, capital market, insurance, and other financial sectors.

Draft rules on capital gains exemption for listed shares released

Khoonming Ho Lewis Lu Key clarifications were made to China's transfer pricing (TP) guidance recently. This included both the finalisation of guidance "localising" the OECD's BEPS TP work for China and clarifications on TP documentation and reporting requirements.

Melissa Lim On April 6 2017, the Australian Treasurer announced the progress made so far of the Australian Taxation Office's (ATO) multinational tax crackdown.