International updates - July/August 2014

Albania: Albanian transfer pricing regulations

Argentina: Case law against minimum notional income tax

Bosnia and Herzegovina: Amended law on tax procedures in Republic of Srpska

Brazil: Provisional Measure No 627 converted into Law

Bulgaria: Bulgaria and the US agree on FATCA implementation

Canada: International employees with stock options

Chile: Proposed taxation on an attributed basis

China: Definition of beneficial owner under entrusted investments

Cyprus: The Cabinet of Cyprus passes Bill for the formation of Unified Single Tax Authority

EU: Hybrid loan arrangements: EU agrees to amend the Parent-Subsidiary Directive

Germany: Global-China cash pooling and transfer pricing implications

Greece: Amendments to withholding tax regime applicable to Greek and foreign affiliated legal entities

Hong Kong: Hong Kong and the source of profits

India: Ruling on seconded employees creating Service PE in India

Italy: Green light given to deductibility of interest expenses for real estate companies involved in the shopping mall business

FYR Macedonia: FYR Macedonia changes tax treatment of uncollected loans

Mexico: Proposed income on hydrocarbons law

New Zealand: Inland Revenue issues rulings on availability of foreign tax credits for tax paid by Australian limited partnerships

Poland: Introducing one of most unorthodox CFC systems in the world? No local capital gains participation exemption

South Korea: Recent developments on the implementation of US FATCA in South Korea

Spain: Spanish government presents tax reform package

Switzerland: Swiss views on BEPS

US Inbound: Anti-inversion Bills and inbound acquisitions