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Urs Kapalle, head of tax and fiscal policy at the Swiss Bankers Association (SBA) in Basel, and Dominic Gubler, tax counsel at the SBA, look at tax transparency and information sharing initiatives involving Switzerland, assessing FATCA and automatic exchange of information from the Swiss perspective and highlighting the past, present and future activities relating to implementation of the country’s tax transparency strategy.

Sandy Bhogal, head of tax at Mayer Brown in London, outlines where we stand with respect to recent multilateral work to counter base erosion and profit shifting (BEPS) and, specifically, Action 4 of the OECD Action Plan, after first pausing to reflect on how and why we got to this point. Conceptually, Action 4 sought to consider ways to reduce base erosion that can occur through interest payments and other economically equivalent amounts.

Alexander Linn Thorsten Braun The German Federal Tax Court (Bundesfinanzhof, BFH) issued a decision (case ref. I R 29/14) on September 9 2015, in which it held that the domestic transfer pricing rules may not be applied to disallow a write-down of an impaired related-party debt in a case where a relevant tax treaty includes the arm's-length standard provisions of Article 9 of the OECD model treaty.

Sabrina Wong Evan Schmid On July 31 2015 the Supreme Court of Canada (SCC) issued its decision in Guindon v Canada, 2015 SCC 41. The substantive legal issue before the SCC was whether the penalty under section 163.2(4) of the Canadian Income Tax Act (ITA) was a criminal sanction such that procedural protections in the Canadian Charter of Rights and Freedoms (Charter) should be engaged and the penalties vacated.

Christos Bourkoulas Transfer pricing (TP) has become a key area for businesses' tax affairs, tax auditors and tax policy-makers. In light of the fiscal situation in Greece, ambitious revenue targets deriving from TP audits have been set and TP related actions for the purpose of fighting tax evasion have been included in the latest memorandum of understanding (MoU) signed between the European Commission and Greece for a three year European Stability Mechanism programme. In this ever-changing environment, multinational businesses have at their disposal a new tool – in the form of the advance pricing agreement (APA) programme – that may manage TP related risks and enable them to mitigate the risk of TP disputes in a proactive manner in cooperation with the tax authorities.

Samantha Schmitz-Merle On October 14, the Luxembourg Government presented its 2016 Budget, containing certain tax measures to be introduced in 2015 and 2016. A progressive reduction of the Luxembourg corporate income tax rate has also been announced for 2017 but no further details have been provided.

India is gearing towards the introduction of a goods and services tax (GST), a destination-based consumption tax, replacing several central and state taxes.

Petter Gruner Henrik Brødholt On October 7 2015, the Norwegian government presented the 2016 Budget to parliament. The key tax proposals in the 2016 Budget relevant for foreign corporate investors are as follows:

Mark Galea Salomone Donald Vella Malta's Budget for 2016, presented to Parliament on 12 October 2015, includes a number of measures which will have an impact on the tax landscape. The Bill incorporating a number of the measures announced in the Budget was put forward to Parliament on October 13 2015 but it is still subject to parliamentary approval. An outline of the salient features of some of the measures contemplated in the Budget, as well as measures that have already made their way into the Bill, are discussed below.

Myranda Chatzimatthaiou On May 13 2015, during the 24th annual meeting of the European Bank for Reconstruction and Development (EBRD) in Tbilisi, Georgia and Cyprus signed an agreement for the avoidance of double tax payment (double tax treaty).