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New Zealand: New Zealand issues draft guidance on BEPS-related reforms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US Inbound: Altera decision reversal withdrawn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

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