International updates - December/January 2016

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International updates - December/January 2016

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The latest international updates from our correspondents around the world.

Albania: Treaty analysis: Albania and Kosovo sign new double taxation agreement

Argentina: Argentina and Mexico sign double tax treaty

Australia: Tax reform topics continue to dominate political scene in Australia

Brazil: Update on the obligation to disclose certain transactions in Brazil

Bulgaria: Treaty analysis: Bulgaria and UK sign new double taxation agreement

Canada: Canadian Federal Court pulls the reins in (slightly) on foreign information requests

Chile: Applicability of the beneficial owner concept for dividends in Chile

Chile: Chilean IRS’s Anti-avoidance Bureau and the Administrative Consultation Procedure

Cyprus: Post-sanctions Iran: Exploring the Iranian market via Cyprus

EU: European Commission issues final decisions in Starbucks and Fiat state aid cases

Germany: Exemption to Germany’s change-in-ownership rules expanded

India: India continues to promote domestic business environment

Indonesia: Indonesia issues a draft Bill for national tax amnesty; plans to cut taxes

Ireland: Ireland confirms AT1 instruments treated as debt

Italy: Companies migrating to Italy: New ‘internationalisation’ decree introduces rules to determine assets and liabilities’ tax basis

FYR Macedonia: Treaty analysis: FYR Macedonia ratifies double taxation agreement with Vietnam

Malta: Malta concludes treaty with Curaçao

Middle East: New incentives for foreign corporations in Kuwait

Montenegro: New VAT exemption incentives in Montenegro

New Zealand: New Zealand introduces Bill to impose GST on cross-border services

Poland: VATable and non-VATable transactions in Poland – allocation of input VAT

Russia: Russian conduit companies – do your sub-holding companies have substance?

Serbia: Treaty analysis: Serbia and Norway double taxation agreement

Spain: Spain opens door to impose penalties on contrived acts or transactions

Switzerland: Switzerland is likely to remain a premier group financing location post-BEPS

Ukraine: Ukraine amends list of low-tax jurisdictions

US Inbound: US issues new guidance on allocation of income

more across site & shared bottom lb ros

More from across our site

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Among the arrivals is Andrew Howell, who leaves scandal-hit PwC Australia after representing PepsiCo in a high-profile TP dispute
ITR's podcast examines whether the big four have overarching cultural issues and assesses the competitive threat of technology-backed transfer pricing firms
The UK advisory firm has seen its global revenues expand by £27.2m following its listing and acquisition of Baker Tilly South-East Europe
Tax-trained John Sams, previously the firm’s CFO and COO, was appointed after a rigorous process, KPMG said
From Mauritius substance rules to Kenyan SEP tax and South African anti-avoidance measures, businesses must navigate growing scrutiny of cross-border IP structures in Africa
ITR spoke to multinationals, advisers and software providers about a June 30 deadline defined by faulty portals, high compliance costs and hard lessons
After years of onerous pillar two prep, businesses will be galled in seeing tax revenues outweighed by compliance costs
Tax advisers should revisit India secondment arrangements after the EY US ruling strengthened the Centrica precedent and raised fresh withholding concerns
Despite the shortfall, effective tax rates of multinationals have seen a ‘statistically significant rise’
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