International updates - October 2014

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International updates - October 2014

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The latest international updates from our correspondents around the world.

Bosnia and Herzegovina: Excise law amended in Bosnia and Herzegovina

Brazil: New divergent decisions regarding taxation of merger of shares

Bulgaria: Amendments to the Bulgarian Public Procurement Act

Canada: Amendments to Canadian international tax proposals

Chile: Final approval for Chilean tax reform package expected next month

China: Notice on further strengthening corporate tax collection and administration on equity transfer

Cyprus: Double taxation agreement between Cyprus and Switzerland

EU FTT: End of the beginning, or beginning of the end?

Germany: Loss relief deferral unconstitutional?

Greece: Challenges in preparing Greek transfer pricing documentation

Hong Kong: Corporate residence determines source of director’s fees

India: Ruling on taxation of indirect transfer

Italy: New tax incentives for cultural activities and tourism sectors

Luxembourg: Recent tax treaties and protocols ratified by Luxembourg

FYR Macedonia: FYR Macedonia adds new product categories to the preferential VAT rate regime

Malta:Malta clarifies taxation of fees paid to non-resident investment committee members

Mexico: New miscellaneous rules introduce additional flexibility on the Mexican maquila regime

New Zealand: High Court rules on residency test for individuals

Poland: Proposal of amendments to VAT Act intended to fight fiscal frauds

Romania: Capital gains tax reporting

Serbia: Serbia – Armenia treaty ratified by Serbian parliament

South Africa: Tax exposure in respect of derivative income earned by non-residents

Switzerland: Swiss non-financial entities and new bank forms – everyone must tick a box

Ukraine: Ukraine tightens currency control rules

US Inbound: Inbound debt limitations

US Outbound: US Tax Court holds EC fine non-deductible under section 162(f)

more across site & shared bottom lb ros

More from across our site

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
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
Tom Goldstein, who was represented by US law firm Munger, Tolles & Olson, denied wilfully cheating on his taxes and blamed errors on his staff
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
The profession is fundamentally restructuring itself around what tax and accounting work should be, a Thomson Reuters leader told ITR
The big four firm is consolidating 16 entities across the region to create a single 6,000-partner behemoth
Brazil’s tax reform unifies consumption taxes to simplify rules, centralise administration and reduce legal uncertainty
The ever-expansive firm has once again attracted a former ‘big four’ talent to lead the new offering
The amended double taxation avoidance agreement removes France’s most favoured nation status for tax treaty benefits
The levies extended beyond the president’s ‘legitimate reach’, the Supreme Court ruled
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