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Alvaro Pereira Mark Conomy On April 29 2016, the Interpretative Declaratory Act 3/2016 (ADI 3/2016) was published, providing for the Brazilian Federal Revenue Authorities' (RFB) position that the increased progressive tax rates in relation to capital gains derived by individuals (and non-residents) should only apply from January 1 2017.

Lorenzo Gálmez Paula Silva While the 2014 Tax Reform Act, N° 20.780, limited the full use of corporate income tax credit (known in Chile as First Category Tax Credit) to foreign taxpayers who were tax residents of countries with which Chile had double tax treaties (DTT) already in force, the "Simplification" Tax Reform Act, N° 20.899 of 2016, extended such benefit to residents of countries with which Chile has signed a DTT even if they are not yet in force, though same conditions.

Jim Fuller David Forst We discussed parts of the new US Model in our March 2016 column. The 2016 US Model Treaty also contains a number of changes to article 22 dealing with the limitations on benefits (LOB) provisions.

Jock McCormack The Australian Government continued attacking multinational tax avoidance with its 2016-2017 Federal Budget released on May 3 2016. The announced measures include a 40% diverted profits tax on large multinationals from July 1 2017, akin to the UK diverted profits tax.

Freddy Karyadi Luna Puspita To encourage economic growth equitable and accelerate development in certain regions, and foreign and domestic capital investments in specified business fields, certain income tax facilities are given to taxpayers who make new investments or expand their existing business in specified business fields and/or certain regions.

André Claes David McNeil Sarah Drye The evolution of the global tax environment is forcing international tax functions to consider new and innovative ways of effective management. Deloitte recently conducted a survey of more than 50 Swiss groups (http://goo.gl/1znlvd) related to how they manage their tax affairs, specifically addressing the impact of the OECD's Base Erosion and Profit Sharing (BEPS) project on tax management.

Trond Eivind Johnsen "Norway has failed to fulfil its obligations arising from Article 31 of the EEA Agreement", states the EFTA Surveillance Authority (ESA) in a letter of formal notice to the Norwegian Ministry of Finance dated May 4 2016. The reason is Norway's interest limitation rules combined with the group relief rules

After years of negotiations, India and Mauritius have signed a protocol which makes important changes to the over three-decades-old tax treaty between the countries.

Sean Foley Cameron Taheri The IRS recently released its 2015 statistics for advance pricing agreements (APAs) and mutual agreement procedure (MAP) results for the Advance Pricing and Mutual Agreement ("APMA") Program.

Alexander Linn Thorsten Braun Germany's controlled foreign corporation (CFC) rules apply to CFCs earning passive income that is taxed at a rate of less than 25%. However, the rules do not apply to subsidiaries located in the EU/EEA if the Germany taxpayer can demonstrate that the subsidiary carries on a genuine economic activity in its state of residence (Cadbury-Schweppes exception, see ECJ, C-196/04). There is scant case law on what constitutes a genuine economic activity for these purposes.