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International updates - March 2016

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The latest international updates from our correspondents around the world.

Albania: Albania and Morocco sign tax treaty

Brazil: Brazilian Federal Revenue Agency publishes tax decision on contribution of know-how into capital

Brazil: Brazil introduces regularisation programme for certain assets held abroad

Canada: Canadian voluntary disclosure programme rises in popularity

Chile: Chile’s new (not-so-)thin capitalisation rules

China: China’s 150% super deduction regulation

Cyprus: Reduced withholding tax rate on dividends from Russia to Cyprus

Georgia: Cyprus – Georgia tax treaty enters into force

Germany: German Federal Tax Court questions constitutionality of interest deduction limitation rule

Indonesia: Indonesia updates Asian treaty network; issues foreign customers’ exchange of information for financial institutions

Italy: Italy enhances IP regime and introduces grandfathering period for trademarks

Luxembourg: Luxembourg and the new face of the Russian tax realm

FYR Macedonia: FYR Macedonia and Israel sign tax treaty

Malta: Malta publishes Common Reporting Standard guidelines

Montenegro: Montenegro’s tax treatment of foreign corporate executives

New Zealand: New Zealand continues tax administration reform

Norway: Foreign rig owner wins Norway Supreme Court case concerning limited tax liability

Poland: Poland introduces new R&D tax incentives

Serbia: Serbia signs 66th double tax treaty

Spain: Control of state aid in Canary Islands investments

Switzerland: Swiss securities transfer tax – No new treatment for Swiss fund managers

Turkey: Constitutionality of the Turkish withholding tax rules: new decision, old school approaches and still a lack of legality

US Inbound: US revises treaty model

US Outbound: US issues proposed CbCR regulations

more across site & bottom lb ros

More from across our site

The UN may be set to assume a global role in tax policy that would rival the OECD, while automakers lobby the US to change its tax rules on Chinese materials.
Companies including Valentino and EveryMatrix say the early adoption of EU public CbCR rules could boost transparency of local and foreign MNEs, despite the short notice.
ITR invites tax firms, in-house teams, and tax professionals to make submissions for the 2023 ITR Tax Awards in Asia-Pacific, Europe Middle East & Africa, and the Americas.
Tax authorities and customs are failing multinationals by creating uncertainty with contradictory assessment and guidance, say in-house tax directors.
The CJEU said the General Court erred in law when it ruled that both companies benefitted from Italian state aid.
An OECD report reveals multinationals have continued to shift profits to low-tax jurisdictions, reinforcing the case for strong multilateral action in response.
The UK government announced plans to increase taxes on oil and gas profits, while the Irish government considers its next move on tax reform.
War and COVID have highlighted companies’ unpreparedness to deal with sudden geo-political changes, say TP specialists.
A source who has seen the draft law said it brings clarity on intangibles and other areas of TP including tax planning.
Tax consultants say companies must not ignore financial transactions in their TP policies as authorities, particularly in the UK, become more demanding.