International updates - March 2016

March 11 2016

The latest international updates from our correspondents around the world.

Albania: Albania and Morocco sign tax treaty

Brazil: Brazilian Federal Revenue Agency publishes tax decision on contribution of know-how into capital

Brazil: Brazil introduces regularisation programme for certain assets held abroad

Canada: Canadian voluntary disclosure programme rises in popularity

Chile: Chile’s new (not-so-)thin capitalisation rules

China: China’s 150% super deduction regulation

Cyprus: Reduced withholding tax rate on dividends from Russia to Cyprus

Georgia: Cyprus – Georgia tax treaty enters into force

Germany: German Federal Tax Court questions constitutionality of interest deduction limitation rule

Indonesia: Indonesia updates Asian treaty network; issues foreign customers’ exchange of information for financial institutions

Italy: Italy enhances IP regime and introduces grandfathering period for trademarks

Luxembourg: Luxembourg and the new face of the Russian tax realm

FYR Macedonia: FYR Macedonia and Israel sign tax treaty

Malta: Malta publishes Common Reporting Standard guidelines

Montenegro: Montenegro’s tax treatment of foreign corporate executives

New Zealand: New Zealand continues tax administration reform

Norway: Foreign rig owner wins Norway Supreme Court case concerning limited tax liability

Poland: Poland introduces new R&D tax incentives

Serbia: Serbia signs 66th double tax treaty

Spain: Control of state aid in Canary Islands investments

Switzerland: Swiss securities transfer tax – No new treatment for Swiss fund managers

Turkey: Constitutionality of the Turkish withholding tax rules: new decision, old school approaches and still a lack of legality

US Inbound: US revises treaty model

US Outbound: US issues proposed CbCR regulations

Topics

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Indirect Tax

US tariffs

This month in indirect tax: Tariff refund delays may cost US taxpayers $700m per month

A 120-plus-day delay to refunds would cost taxpayers almost $3bn in additional interest, the Cato Institute warned; plus indirect tax updates from February

Sam Sholli, March 04 2026

Direct Tax

UK pound,money of United kingdom close up on white, Pound UK not

US pillar two side-by-side deal will cost UK £700m per year

The Office for Budget Responsibility’s pessimistic pillar two forecast accompanied the UK chancellor’s muted Spring Statement, dubbed ‘as dull as possible’ by one adviser

Tom Baker, March 03 2026

Direct Tax

Nobel prize

Creative destruction and digital tax: reflecting on the 2025 Nobel Prize

Digital tax reform is dissolving the old ‘temporal buffer’, forcing systems, institutions, and professionals to adapt as real-time reporting reshapes governance, capability, and compliance

Nitin Agarwal, March 03 2026

Podcasts

Editable TT 640x360 article-thumbnail (2).png

Taxing Times: introducing ITR’s new monthly podcast

Our first instalment features analysis of Deloitte’s landmark EMEA merger, Donald Trump’s Supreme Court tariff showdown and Venezuela’s tax evolution

Tom Baker, March 02 2026

Direct Tax

‘Potential to raise standards’: mixed adviser reaction to HMRC registration system

While some believe it could have a positive effect on the wider advisory landscape, others argue that HMRC’s ‘red tape’ exercise won’t deter bad actors

Sam Sholli, March 02 2026

Direct Tax

Pillar two is revising global tax competition with a 15% minimum tax rate

A taxing week: Pillar two will prosper despite US side-by-side arrangement

The political optics of the US’s carve-out deal are poor, but as the Fair Tax Foundation’s Paul Monaghan writes, it preserves pillar two’s guiding ethos

Paul Monaghan, February 27 2026

Direct Tax

This week in tax: PwC commences legal battle with boutique consultancy founded by ex-COO

The big four firm reportedly sent ‘threatening’ correspondence to Unity Advisory over its hiring of ex-PwC partners; plus tax recruitment news from the week

Sam Sholli, February 27 2026

Direct Tax

Washington DC Capitol view on cloudy sky background

Ex-US Supreme Court advocate convicted on 12 counts in tax trial

Tom Goldstein, who was represented by US law firm Munger, Tolles & Olson, denied wilfully cheating on his taxes and blamed errors on his staff

Sam Sholli, February 26 2026

Transfer Pricing

Suited figure pointing to audit among various hexagonal icons

TP documentation in a fragmented world: how to limit audit triggers

Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions

Daniel Moalusi, February 26 2026

Direct Tax

Elizabeth-Beastrom resized.jpg

‘Tax at breaking point’: Thomson Reuters’ AI tech hits one million users

The profession is fundamentally restructuring itself around what tax and accounting work should be, a Thomson Reuters leader told ITR

Sam Sholli, February 24 2026