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A $6.4 billion bill has landed on taxpayers’ MATs A seemingly positive exemption on Indian minimum alternative tax (MAT) for foreign portfolio investors turned sour when Prime Minister Narendra Modi announced back-taxes of more than $6.4 billion on 100 foreign investors into India, with thousands more still at risk. The announcement has caused some investors to decry the government's promises of a taxpayer-friendly regime. In his Budget speech in February, Finance Minister Arun Jaitley announced that foreign investors would be MAT exempt from April 1 2015, though did not immediately make clear that investors would face tax bills on transactions before this date. Amid earlier concerns about tax liabilities, the Indian government assured foreign investors they would not be liable for the tax, which was introduced for the sole purpose of taxing domestic Indian companies. However, asset managers and other investors are now worried that tax demands from the Indian authorities will soon be landing on their desks.

Modifications to the French-German agreement set in motion changes elsewhere Changes to the double tax treaty (DTT) between France and Germany are unexpectedly affecting real estate investment trusts (REITs). The amendments can be seen as a precursor to upcoming changes to the France-Belgium and France-Netherlands DTTs, and also as evidence of a German- and BEPS-driven trend of closing the door on some REIT tax exemptions.

Arif Çelen of WTS & Çelen in Turkey looks at the significant tax and legal considerations relevant for taxpayers operating, or planning to operate, in the real estate sector in Turkey.

Partho Shome’s 30-year career as a tax official and adviser to Indian governments and multilateral organisations may be at an end for now, but he will still take a keen interest in tax policy, as this exclusive interview with International Tax Review reveals.

Mark Lindley, head of tax at the Qatar Financial Centre (QFC), looks at investment opportunities across the Gulf Cooperation Council (GCC) as the region moves away from a reliance on oil and prepares to host global events like the FIFA World Cup. He also tackles the resultant controversy concerns that could lead to tax disputes.

Read this month's special features on Turkey and GCC

James Newnham After an intense month of tax-related Australian Senate Economics Committee hearings, namely an inquiry taking evidence on corporate tax avoidance, Apple, Google and Microsoft as well as leading Australian mining companies were in the spotlight to answer allegations around international profit shifting. In this context, the Australian tax regime is under increasing public pressure to keep up with the effects of ubiquitous digital disruption. In this regard, Australian Treasurer Joe Hockey has flagged plans for the so-called 'Netflix tax' to extend the reach of the GST to the online purchase of movies, songs, books and streaming services, consistent with the G20/OECD destination principle. The plan would update the GST to include intangible services such as online downloads and could set a precedent which extends to other digital and editorial content. On March 30 2015, the Australian government released its 'Re:think' tax discussion paper, following on from the 2015 Intergenerational Report, contemplating a renewed tax system that supports higher economic growth and living standards, improves international competitiveness and adjusts to a changing economy. In releasing the paper, the Treasurer also said the government "does not support high tax rates to deliver these outcomes. As we have said on numerous occasions, our nation will never be able to tax its way to prosperity.". Hockey said the "challenge then is to reform our tax system so that we can raise necessary revenue without detracting from continued economic growth across the Australian economy". The key points of the paper discuss and consider reforms to the rate and base of the GST, the (high) corporate tax rate and inefficient taxes such as stamp duty.

Bob van der Made With the fight against aggressive tax planning, tax fraud, tax avoidance and tax evasion having become a policy priority for the EU, the European Parliament is upping the ante in the heated debate on tax rulings and calls for more tax transparency. On February 12 2015, the European Parliament decided to set up a special committee on tax rulings and other measures similar in nature or effect (TAXE) "to examine practice in the application of EU state aid and taxation law in relation to tax rulings and other measures similar in nature or effect issued by member states, if such practice appears to be the act of a member state or the Commission". The special committee's mandate is therefore to analyse and examine how EU state aid rules have been applied by the Commission to tax rulings in member states since January 1 1991 (this seems inspired by the Commission's ongoing state aid investigation into Apple; otherwise this date seems arbitrary), and member states' compliance with the EU's directives on mutual assistance (1977) and on administrative cooperation in tax matters (2011), in particular with regard to the spontaneous exchange of information on tax rulings. It should be noted, however, that member states are only effectively obliged to spontaneously exchange information on cross-border tax rulings under certain circumstances under the EU Directive on administrative cooperation in tax matters since 2013. According to the Commission's statistics, member states haven't actually really done this in practice, however.

Alvaro Pereira and Mark Conomy (pictured) On April 1 2015, the Brazilian Government issued Decree 8,426/2015, regulating the Social Integration Program (PIS) and the Social Contribution on Billing (COFINS) applied on financial revenues, including financial revenue derived from hedge transactions, with effect from July 1 2015. By way of background, PIS and COFINS under the non-cumulative regime are social contributions levied on gross revenues within Brazil (subject to certain specified exemptions) at the combined rate of 9.25%. Financial revenue has been granted a 0% combined rate since April 2005.