International briefing for July 2018

Brexit has been dominating the headlines, with the publication of the UK government’s white paper on future relations with the EU and two Brexit-related bills passing through the House of Commons. The OECD has published discussion drafts on transfer pricing matters. Further countries have signed or ratified the BEPS multilateral instrument. In the EU, there have been two tax cases decided by the CJEU, and two member states have taken steps to implement ATAD. In local country news, Italy has provided guidance on R&D tax credits, while India provided guidance on the ‘place of effective management’ rules for foreign companies. On digital tax, the EU has promised ‘a modern and balanced regulatory framework’ for the digital economy; and the US Supreme Court has ruled that physical presence is no longer a prevailing standard that can be relied on by taxpayers for US state sales and use tax purposes.