International updates - October 2018

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International updates - October 2018

International Updates

The latest international updates from our correspondents around the world.

Albania: Albania changes income tax law, introduces incentives for agro-tourism

Australia: MLI, hybrid mismatch, MITs and staple structures, cross-border financing and reduced company tax rate

Brazil: Amendments to protocol to Brazil and Argentina tax treaty enacted

Bulgaria: Bulgaria allows electronic storage of employment documents

Canada: ‘Partnerships’ in Canada

Chile: Chile aiming to join era of indirect tax on digital services

China: Tax support for innovation and new regulatory framework for e-commerce

Croatia: Tax incentives for research and development in Croatia

Egypt: Central Bank of Egypt defends bank accounts secrecy

European Union: Outgoing Juncker commission’s plans for tax until November 2019

Georgia: Georgia concludes double taxation treaty with Saudi Arabia

Germany: Using statistical analysis to improve TNMM

Hong Kong: Recent accounting changes in Hong Kong

India: Tax treaty benefits are available even without providing a tax residency certificate (TRC)

Indonesia: Commencement of AEOI and priority target for tax audit

Italy: Intercompany charges, cost inherence and deductibility

Luxembourg: VAT committee publishes guidelines on VAT treatment of cash pooling

Montenegro: Citizenship by investment in Montenegro

Netherlands: Dutch participation exemption and the write-down of receivables

New Zealand: New Zealand issues draft guidance on BEPS-related reforms

Poland: Income tax on buildings: Amendments

Portugal: Liquidation proceeds sourced in Spain and exemption method for non-habitual tax residents in Portugal

Romania: Tax audits - a disruptive routine for every taxpayer

Serbia: Serbia amends VAT Law, extending eligibility for VAT refund to foreign companies

South Africa: Dividend stripping rules: Impact on liquidations and cross-border share buybacks

Switzerland: EU DAC6 mandatory disclosure rules - why should Swiss intermediaries care?

Turkey: Recent tax developments

US Inbound: Altera decision reversal withdrawn

US Outbound: New updates to CAP focus on transfer pricing issue resolution

more across site & shared bottom lb ros

More from across our site

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Kristine Riisberg warned that TP decisions can determine top-up tax exposure under pillar two, while global consensus over the rules remains unsettled
Both Germany’s NIS2 and the EU AI Act now determine whether a tax function can meet its obligations – and both can make management personally accountable
Originators, loan purchasers and securitisation vehicles may need to revisit servicing agreements and pricing after a key judgment narrowed the VAT credit management exemption
Opening doors for existing talent within Baker McKenzie and a desire for enhanced legal capabilities informed Ricardo Perera’s switch from KPMG
Boaz Goren’s move to the upstart PE-backed firm takes the number of senior UK tax professionals who have left EY this year to 13
The allegations against Deloitte Cyprus raise uncomfortable questions about how far the big four can distance themselves from misconduct at member firms
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