International updates - October 2018

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International updates - October 2018

International Updates

The latest international updates from our correspondents around the world.

Albania: Albania changes income tax law, introduces incentives for agro-tourism

Australia: MLI, hybrid mismatch, MITs and staple structures, cross-border financing and reduced company tax rate

Brazil: Amendments to protocol to Brazil and Argentina tax treaty enacted

Bulgaria: Bulgaria allows electronic storage of employment documents

Canada: ‘Partnerships’ in Canada

Chile: Chile aiming to join era of indirect tax on digital services

China: Tax support for innovation and new regulatory framework for e-commerce

Croatia: Tax incentives for research and development in Croatia

Egypt: Central Bank of Egypt defends bank accounts secrecy

European Union: Outgoing Juncker commission’s plans for tax until November 2019

Georgia: Georgia concludes double taxation treaty with Saudi Arabia

Germany: Using statistical analysis to improve TNMM

Hong Kong: Recent accounting changes in Hong Kong

India: Tax treaty benefits are available even without providing a tax residency certificate (TRC)

Indonesia: Commencement of AEOI and priority target for tax audit

Italy: Intercompany charges, cost inherence and deductibility

Luxembourg: VAT committee publishes guidelines on VAT treatment of cash pooling

Montenegro: Citizenship by investment in Montenegro

Netherlands: Dutch participation exemption and the write-down of receivables

New Zealand: New Zealand issues draft guidance on BEPS-related reforms

Poland: Income tax on buildings: Amendments

Portugal: Liquidation proceeds sourced in Spain and exemption method for non-habitual tax residents in Portugal

Romania: Tax audits - a disruptive routine for every taxpayer

Serbia: Serbia amends VAT Law, extending eligibility for VAT refund to foreign companies

South Africa: Dividend stripping rules: Impact on liquidations and cross-border share buybacks

Switzerland: EU DAC6 mandatory disclosure rules - why should Swiss intermediaries care?

Turkey: Recent tax developments

US Inbound: Altera decision reversal withdrawn

US Outbound: New updates to CAP focus on transfer pricing issue resolution

more across site & shared bottom lb ros

More from across our site

The controversial deal will allow US-parented groups to be carved out from key aspects of pillar two
Awards
ITR invites tax firms, in-house teams, and tax professionals to make submissions for the 2027 World Tax rankings and the 2026 ITR Tax Awards globally
Pillar two was ‘weakened’ when it altered from a multinational convention agreement to simply national domestic law, Federico Bertocchi also argued
Imposing the tax on virtual assets is a measure that appears to have no legal, economic or statistical basis, one expert told ITR
The EU has seemingly capitulated to the US’s ‘side-by-side’ demands. This may be a win for the US, but the uncertainty has only just begun for pillar two
The £7.4m buyout marks MHA’s latest acquisition since listing on the London Stock Exchange earlier this year
ITR’s most prolific stories of the year charted public pillar two spats, the continued fallout from the PwC Australia tax leaks scandal, and a headline tax fraud trial
The climbdowns pave the way for a side-by-side deal to be concluded this week, as per the US Treasury secretary’s expectation; in other news, Taft added a 10-partner tax team
A vote to be held in 2026 could create Hogan Lovells Cadwalader, a $3.6bn giant with 3,100 lawyers across the Americas, EMEA and Asia Pacific
Foreign companies operating in Libya face source-based taxation even without a local presence. Multinationals must understand compliance obligations, withholding risks, and treaty relief to avoid costly surprises
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