International updates - November 2016

November 02 2016

The latest international updates from our correspondents around the world.

Albania: Albanian transfer pricing regulations

Australia: Australia increases focus on MNE tax avoidance and BEPS initiatives

Brazil: Brazil updates tax haven and privileged tax regime lists

Bulgaria: Bulgarian transfer pricing regulations

Canada: Canada introduces draft legislation to broaden back-to-back rules to character substitution transactions

Chile: Tax treatment for cloud computing services provided without a license

China: China’s recent measures to comply with BEPS, CRS and the New Silk Road

Croatia: Croatian transfer pricing regulations

Curaçao: Tax rules for businesses to change as budget law is approved by parliament

Cyprus: Cyprus and Latvia sign DTA

Germany: CJEU asked to rule on German anti-treaty shopping rule

Greece: Uncertain application of Greece’s network of double tax treaties

Hong Kong: New guidance for corporate treasury centres in Hong Kong

India: Tax amortisation of goodwill

Indonesia: Google in Indonesia

Ireland: Ireland updates its international tax strategy

Luxembourg: Real estate funds: VAT exemption for fund management services

Malta: Release of the 2017 budget

Mexico: Mexican Supreme Court of Justice rules against taxpayers on deduction limits and electronic accounting

New Zealand: New Zealand Inland Revenue expands monitoring of large taxpayers

Norway: Corporate tax cut and new financial activities tax announced in Norway’s 2017 state budget

Poland planning significant VAT changes in 2017

Romania: Romanian individual tax residency position

Serbia: Kazakhstan Senate approves DTA with Serbia

South Korea: Another taxpayer win at the Supreme Court on a beneficial ownership case

Spain: Potential recovery of Spanish energy taxes

Switzerland: UK’s hybrid mismatch rules to impact Swiss entities

US Inbound: US Treasury issues final regulations on tax treatment of corporate debt

Topics

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Artificial intelligence

A taxing week: AI is reshaping capital flows and toppling the old tax order

Governments are rewriting tax policy for the AI era, deploying digital taxes, tailored incentives and algorithmic enforcement that redefine where value is created

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This week in tax: KPMG announces Gary Wingrove as new global chairman and CEO

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Transfer Pricing

‘Clear limitations’: Italian advisers differ on intra-group financing TP ruling

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As GCCs increasingly become strategic hubs, multinationals face heightened risks around permanent establishment and place of effective management

Mehul Jain, March 19 2026

Direct Tax

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‘Kept the family together’: EU tax chief praises US/OECD pillar two deal

While all options presented ‘drawbacks’, European Commission tax leader Wopke Hoekstra said the controversial US carve-out deal has ‘many benefits’

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Direct Tax

FAQs

The pillar two side-by-side agreement: key questions answered

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Direct Tax

Alex Cobham, Paul Monaghan

Tax campaigners clash on pillar two as side-by-side deal costs emerge

Despite estimates that the US/OECD agreement will cost countries billions, the Fair Tax Foundation’s Paul Monaghan believes the deal is a ‘necessary evil’

Sam Sholli, March 16 2026