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International review for May 2019

Speed read
Cooperative compliance programmes are becoming increasingly en vogue: the early signs are that HMRC’s profit diversion compliance facility has been a success; and Italy has introduced a new cooperative compliance programme for ascertaining permanent establishment (PE) status targeted at large multinationals. The Crown dependencies have jointly issued long-awaited draft guidance notes on the economic substance requirements which came into force from the beginning of 2019. The latest incarnation of Swiss tax reform passed a public vote and will come into effect from 1 January 2020. A public consultation has begun on proposed amendments to the profit attribution rules for PEs in India. France and the Czech Republic have continued to drive forward with unilateral measures on digital taxation.

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