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New Zealand: New Zealand issues draft guidance on BEPS-related reforms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US Inbound: Altera decision reversal withdrawn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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Maintaining increased funding for HMRC is a ‘high possibility’ if he becomes PM, ITR has also heard
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2026 Europe Tax Awards
The firm has hired a team of private client lawyers from Withers to launch in New York and Connecticut, though ITR analysis suggests it faces stiff competition
The ability of tax authorities to receive and analyse data is becoming ‘quite advanced’, warns Stuart Lang, head of EY’s compliance co-sourcing solution
The Court of Appeal ruling clarifies that treaty benefits are not abusive where transactions are commercially driven, providing greater certainty on “main purpose” anti-avoidance tests
Despite the Netherlands featuring an unusual concentration of World Tax-ranked technology-led providers, sources believe there’s a long way to go to challenge the established players
Ethics seems to be playing a subservient role to an entitlement culture borne out of a pervasive ‘revenue at all costs’ mentality at the big four
Historical World Tax data suggests the ‘largest law firm merger in history’ may not pose a serious threat to the world's leading tax practices
The repeal of Libya’s statute of limitations and tougher enforcement leave taxpayers navigating a high-stakes choice between conciliation and litigation
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