international tax news. edition 51 may 2017 - pwc · international tax news is a monthly...

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International

Edition 51May 2017

Welcome

international tax developments worldwide

companies. International Tax News is a monthly

world, authored by specialists in PwC’s global

Shi-Chieh ‘Suchi’ Lee

Global Leader International Tax Services Network

T: +1 646 471 5315

E: suchi.lee@us.pwc.com

Tax Legislation Tax Administration

and Case Law

Previous

issues

In this issueSubscriptionProposed Tax

Legislative Changes

Brazil

Brazilian tax authorities issue

on non-resident capital gains upon substitution of shares

China

tax regulationstax on corporations

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Tax Administration and Case LawTax legislation Proposed Tax Legislative Changes

Tax Legislation Tax Administration

and Case Law

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issues

In this issueSubscriptionProposed Tax

Legislative Changes

Brazil

United Kingdom

The UK Finance Bill 2017

Brazil

Disclosure of Brazilian tax rulings under the

information exchange mechanism

Brazil

Brazilian tax authorities issue tax ruling

China

China issues administrative measures for

Special Tax Investigation Adjustments and

Mutual Agreement Procedures

Costa Rica

Costa Rica imposes new annual tax

Hong Kong

Bill on expanding the list of reportable

jurisdictions for AEoI purposes

United Kingdom

UK government triggers mechanism for

leaving the European Union

Canada

2017 Canadian Federal Budget

Brazil

Brazilian tax authorities release guidance

related to the triggering event for withholding

tax and other transactional taxes imposed

on the importation of services

United States

President Trump’s executive order to review

tax regulations

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Brazil

On December 29, 2016, the Brazilian tax authorities issued Normative Instruction (NI) 1,684/2016, which

PwC observation:

Fernando Giacobbo

São Paulo

T: +55 11 3674 2582

E: fernando.giacobbo@br.pwc.com

Ruben Gottberg

São Paulo

T: +55 11 3674 6518

E: ruben.gottberg@br.pwc.com

Tax Administration

and Case Law

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In this issueSubscriptionProposed Tax

Legislative Changes

Tax Legislation

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Brazil

by its Portuguese acronym) issued tax ruling 88/2017

Ruben Gottberg

São Paulo

T: +55 11 3674 6518

E: ruben.gottberg@br.pwc.com

Fernando Giacobbo

São Paulo

T: +55 11 3674 2582

E: fernando.giacobbo@br.pwc.com

PwC observation:

Tax Administration and Case Law

Previous issues

In this issueSubscriptionProposed Tax Legislative Changes

Tax Legislation

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China

Adjustments and Mutual Agreement Procedures (MAP)(SAT Public Notice [2017] No.6, Public Notice 6) to

tax adjustments, and other relevant issues. Public Notice 6

Notice 6 include:

Encouraging enterprises to conduct risk assessment and self-adjustments

•

•

•

•

PwC observation:

Matthew Mui

China

T: +86 10 6533 3028

E: matthew.mui@cn.pwc.com

Tax Administration

and Case Law

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issues

In this issueSubscriptionProposed Tax

Legislative Changes

Tax Legislation

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Costa Rica

PwC observation:

John Salerno

PwC US

T: +1 203 539 5733

E: john.salerno@pwc.com

Jose Leiman

PwC US

T: +1 305 381 7616

E: jose.leiman@pwc.com

Carlos Barrantes

PwC Costa Rica

T: +506 2224 1555

E: carlos.barrantes@cr.pwc.com

Tax Administration

and Case Law

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issues

In this issueSubscriptionProposed Tax

Legislative Changes

Tax Legislation

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was gazetted on March 24, 2017.

•

•

PwC observation:

Fergus WT Wong

Hong Kong

T: +852 2289 5818

E: fergus.wt.wong@hk.pwc.com

Tax Administration

and Case Law

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issues

In this issueSubscriptionProposed Tax

Legislative Changes

Tax Legislation

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Canada

Kara Ann Selby

18 York St., Toronto, ON

T: +1 416 869 2372

E: kara.ann.selby@ca.pwc.com

Maria Lopes

18 York St., Toronto, ON

T: +1 416 365 2793

E: maria.lopes@ca.pwc.com

PwC observation:

Tax Legislation Tax Administration and Case Law

Previous issues

In this issueSubscriptionProposed Tax Legislative Changes

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Robin G Palmer

London, Embankment Place

T: +44 20 7213 5696

E: robin.g.palmer@uk.pwc.com

Sara-Jane Tovey

London, Embankment Place

T: +44 20 7212 2507

E: sara-jane.tovey@pwc.com

by the UK government on March 20, 2017,

Exchequer presented his Spring Budget to Parliament on March 8, 2017. The bill is now progressing through the various stages

it is expected to receive royal assent in the

•

•

•

PwC observation:

The UK Prime Minister, Theresa May, triggered the withdrawal process (under

Paper was issued by the UK government the

intends to convert the ‘acquis’ (i.e. the body

European Communities Act 1972 is repealed so generally the same rules and UK laws will

The UK Parliament will subsequently

scrutiny and proper debate.

PwC observation:

Panny Loucas

London, Embankment Place

T: +44 207 804 0365

E: panny.loucas@pwc.com

Tax Legislation Tax Administration

and Case Law

Previous

issues

In this issueSubscriptionProposed Tax

Legislative Changes

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acronym) issued Normative Instruction (NI) n. 1,689

Brazil

PwC observation:

Fernando Giacobbo

São Paulo

T: +55 11 3674 2582

E: fernando.giacobbo@br.pwc.com

Ruben Gottberg

São Paulo

T: +55 11 3674 6518

E: ruben.gottberg@br.pwc.com

Tax Legislation Previous

issues

In this issueSubscriptionProposed Tax

Legislative Changes

Tax Administration

and Case Law

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Brazil

On March 22, 2017 the Brazilian tax authorities

the income becomes economically or legally available to

PwC observation:

Fernando Giacobbo

São Paulo

T: +55 11 3674 2582

E: fernando.giacobbo@br.pwc.com

Mark Conomy

São Paulo

T: +55 11 3674 2519

E: conomy.mark@pwc.com

Tax Legislation Previous

issues

In this issueSubscriptionProposed Tax

Legislative Changes

Tax Administration

and Case Law

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President Trump signed an executive order on April

United States taxpayers, add undue complexity to the

and proposed and temporary regulations under section

instruments between related parties are treated as debt or equity and regulations under Section 7874 would reduce

PwC observation:

Andrew Prior

Washington, DC

T: +1 202 414 4572

E: andrew.prior@us.pwc.com

Tax Legislation Previous

issues

In this issueSubscriptionProposed Tax

Legislative Changes

Tax Administration

and Case Law

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Shi-Chieh ‘Suchi’ Lee

T: +1 646 471 5315 E: suchi.lee@us.pwc.com

Geoff Jacobi

T: +1 202 414 1390E: geoff.jacobi@us.pwc.com

assurance, advisory and tax services. Find out more and tell us what matters to you by visiting us at www.pwc.com.

This content is for general information purposes only, and should not be used as a substitute for consultation with professional advisors.

Design Services 30663 (05/17).

Tax Legislation Tax Administration

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Legislative Changes

Worldwide Tax Summaries: Corporate taxes 2016/17

If you’re operating globally, are you aware of changes to the myriad tax rates in all the jurisdictions where you operate? If not, we can help – download the eBook of our comprehensive tax guide, or explore rates in over 150 countries using our online tools, updated daily.