International Tax News - August 2014

by DLA Piper


By Matthew Cridland

The Australian Tax Office has released its long awaited public guidance on the Australian tax and GST treatment of bitcoin and other crypto-currencies. This guidance, originally scheduled to be released on June 30, 2014, was delayed while the ATO considered further submissions and sought advice from legal counsel.

The issues raised in the ATO’s guidance will be relevant to all businesses considering trading or making payments with bitcoins in Australia, including businesses considering accepting bitcoins as payment for goods or services.

Find out more about the ATO’s views and the potential risks and options for businesses affected by the guidance.


By Svitlana Musienko and Illya Sverdlov

The Verkhovna Rada, Ukraine’s Supreme Council, has approved amendments to the country’s tax law. Among the changes are amendments affecting the corporate profit tax and excise duty, as well as extensive changes in the VAT system.

A new obligatory payment has also been introduced – the so-called military duty.

Find out more about these significant changes.


From the Tax department of Campos Mello Advogados*

Newly published Brazilian Interpretative Act (Ato Declaratório Interpretativo) N. 7/2014 expresses the Brazilian IRS’s view regarding the tax treatment applicable to cross-border payments for the use of data centers located abroad.

According to the Act, when the Brazilian source of payment hires data centers abroad for the use of storage systems and remote data processing, the transactions may not be characterized as rental, but as typical provision of services, which triggers withholding income tax.

Find out more.



In this globalized business world, whether to enter and surf the China market is no longer a question. The question is how well can one understand the different and continuously evolving China business, legal and tax environment in order to achieve the desired business success.

In this seminar – being offered in three US locations – DLA Piper’s US and China lawyers come together to summarize the latest developments in foreign investment and practice in China. In particular, we will examine the rapid rise of e-commerce in China.

What are the possible business models to sell tangible products into China? Which particular legal, tax and business considerations are key? What have foreign investors done in China so far?

This seminar will cover these critical areas:

Selling to China through e-commerce

Regulatory environment and typical models

Practical issues and solutions

Selling to China through traditional means

Distribution models for selling to China

International tax planning and issues

China tax planning and issues

Speaking at this event will be Paul Chen, DLA Piper’s Head of Corporate, Asia, and Co-head, China Investment Services; Daniel Chan, DLA Piper’s Head of Tax, Asia, and Co-head, China Investment Services; Windson Li, DLA Piper’s Senior Legal and Tax Manager, China Tax and Transfer Pricing; and Eric Ryan, DLA Piper Partner in International Tax.

We hope you will join us for this informative event.

Monday, September 15, 2014
Noon – 2:00 p.m.

Thursday, September 18, 2014
8:30 a.m. – 10:30 a.m.

Tuesday, September 23, 2014
10:00 a.m. – Noon

Register for the San Diego seminar here, the Silicon Valley seminar here, and the Chicago seminar here.

*This article was prepared by the Tax department of Campos Mello Advogados, an independent law firm, which has as tax partners Guido Vinci, Leonardo Homsy and Humberto Marini, based in Rio de Janeiro, and Ana Luiza Martins and Alex Jorge, based in São Paulo.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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