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Fernando Giacobbo Ruben Gottberg On July 27 2017, the Brazilian tax authorities published Normative Instruction 1.722/2017, clarifying that Brazilian affiliates of non-Brazilian multinational enterprises may be required to file the country-by-country report (CbCR) in Brazil, in relation to the fiscal year 2016, even if a CbCR has been filed by either the ultimate parent entity (UPE) or a surrogate entity (SE) in another jurisdiction.

Freddy Karyadi Nina Cornelia Santoso Following the enactment of Government Regulation in Lieu of Law (Peraturan Pemerintah Pengganti Undang-undang, or Perppu) No. 1 of 2017, concerning access to financial information for the interest of taxation on May 8 2017, the House of Representatives have further discussed whether to accept and bring the Perppu to a plenary meeting to be ratified as a law.

Tiago Cassiano Neves Dinis Tracana The Portuguese tax authorities (PTA) issued a ruling on July 21 2017 that has the novelty of providing for the first time some guidance on the interpretation of the permanent establishment (PE) concept for corporate income tax (CIT) proposes in the framework of some operating models. The following is a brief summary of the facts and conclusions underpinning this ruling.

Joe Duffy Tomás Bailey, The Irish Department of Finance published a briefing document in June 2017 that was prepared for the newly appointed Minister for Finance (the Brief). In addition to providing an overview of Ireland's business plan and economic priorities, the Brief provides an updated insight into Ireland's international tax policy.

Ilias Sakellariou The Greek Independent Authority for Public Revenue (IAPR) published on July 24 2017 a decision (POL. 1114/2017) to provide administrative guidance on the Greek tax treatment of foreign trusts and foundations.

Alexander Tokarev Ivan Nasonov In 2015, the 'beneficial owner of income' concept was introduced into the Russian Tax Code. Since 2017, foreign companies claiming treaty benefits in Russia are obliged to provide the Russian companies paying them income with documentary proof of their status as beneficial owners of this income.

Mark Martin Mark Horowitz On July 26 2017, the US Tax Court issued a memorandum opinion in Eaton Corp. v. Commissioner, TC Memo 2017-147 that concluded, in part, that cancellation by the IRS of advance pricing agreements (APAs) was an abuse of discretion.

Burçin Gözlüklü Ramazan Biçer Guidance that details how the Turkish tax authorities will determine whether to call a taxpayer to justify his declaration before initiating a tax audit have finally been released, almost year after this new mechanism was put in place.

Because tax doesn’t have to be taxing. A less-than-serious look back at some of the quirkier tax stories from the past month.

Jim Fuller David Forst The US Tax Court, in Grecian Magnesite Mining, Industrial & Shipping Co, SA v. Commissioner, 149 TC No. 3 (July 13 2017), held that a constructive sale by a foreign person of its interest in a partnership engaged in a US trade or business was not subject to US tax. In so doing, the court dismissed the conclusion of Revenue Rule 91-32 (Rev. Rul. 91-32) that a gain on the sale by a non-US partner of its interest in a partnership should be analysed asset-by-asset and treated as income effectively connected with the conduct of a trade or business (ECI) to the extent the partnership's underlying assets are used in a US trade or business. This ruling has been subject to heavy criticism since it was issued as not being in accordance with the Code and Regulations. The court's holding validates that criticism and positions taken by foreign taxpayers in accordance with the Code and Regulations rather than Rev. Rul. 91-32.