International updates - March 2015

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International updates - March 2015

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The latest international updates from our correspondents around the world.

Australia: Recent court case roundup; Structural reform delayed

Brazil: Increase of PIS and COFINS rates on the importation of goods

Canada: Heads I win, tails you lose: Canada Revenue Agency refuses to refund overpaid tax after statutory limitation periods expire

Chile: Tax credit regarding Chilean sourced income subject to withholding tax in a foreign jurisdiction

China: New regulations to encourage corporate restructuring and investment with non-monetary assets

EU: Update on patent boxes and the EU Code of Conduct Group (Business Taxation)

Germany: Deduction of foreign partner’s interest expense

India: Creation of service PE by activities of employees deputed to India

Ireland: ICAV – Ireland’s new corporate funds vehicle

Italy: New decree extends Patent Box regime to commercial trademarks and introduces tax measures for “indirect lending”

Luxembourg: Luxembourg tax authorities clarify the tax treatment of limited partnerships

Malta: Changes to VAT rules – Telecommunications, broadcasting and electronic services

Mexico: Mexican taxpayers’ advocacy institution issues recommendation on Mexican tax authorities’ requests for notarisation of private documents

Poland: Changes to the Polish corporate income tax law

South Africa: Base erosion and profit shifting – Debt:equity

South Korea: Korean courts narrowly interpret mitigating circumstances for non-compliance with FTA requirements

Spain: Invest not just into, but also from, the Canary Islands

Sweden: US investment funds exempt from Swedish dividend withholding tax under EU law – Swedish Tax Agency decides to not appeal ruling

Switzerland: How Swiss companies should apply the income tests for FATCA classification purposes

US Inbound: Obama releases FY 2016 Budget

more across site & shared bottom lb ros

More from across our site

Belgium’s new coalition government has gone ahead with a new exit tax regime that could land it in the courts.
Brazil’s government has not officially framed the bill as a countermeasure amid trade tensions with the US, but the move is being considered as part of Brazil’s strategic response, one expert tells ITR
Understanding India’s income tax landscape can help charities ensure compliance, optimise tax benefits, and enhance their impact, writes Raghav Bajaj of Khaitan & Co
Tax advisers in Brazil are rising above the country’s notoriously complex tax system to deliver high-quality advisory services, ITR’s exclusive in-house data reveals
ITR’s data has highlighted the US firm’s ambition to become America’s ‘premier’ tax player via a concerted partner recruitment strategy
Jaap Zwaan’s arrival continues a recent streak of A&M Tax investing in the region; in other news, the US and Japan struck a deal that significantly lowered tariff rates
In a world where international tax concepts rely on human activity, Leonard Wagenaar poses existential questions about the future of such ideas when AI is ever-present
France v Axa provides a practical illustration of how the burden of proof is applied in TP matters under French law, ITR also heard
In an exclusive interview with ITR, Ian Gary calls for a central public CbCR database and bemoans the US’s lack of involvement in international tax transparency
Reckitt Benckiser is to divest its Essential Home business, which includes more than 70 brands, to private equity firm Advent International
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