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International updates - December/January 2016


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 & bottom lb ros

More from across our site

The Brazilian government may be about to align the country’s unique system with OECD standards, but this is a long-awaited TP reform and success is uncertain.
Two months since EU political agreement on pillar two and few member states have made progress on new national laws, but the arrival of OECD technical guidance should quicken the pace. Ralph Cunningham reports.
It’s one of the great ironies of recent history that a populist Republican may have helped make international tax policy more progressive.
Lawmakers have up to 120 days to decide the future of Brazil’s unique transfer pricing rules, but many taxpayers are wary of radical change.
Shell reports profits of £32.2 billion, prompting calls for higher taxes on energy companies, while the IMF warns Australia to raise taxes to sustain public spending.
Governments now have the final OECD guidance on how to implement the 15% global minimum corporate tax rate.
The Indian company, which is contesting the bill, has a family connection to UK Prime Minister Rishi Sunak – whose government has just been hit by a tax scandal.
Developments included calls for tax reform in Malaysia and the US, concerns about the level of the VAT threshold in the UK, Ukraine’s preparations for EU accession, and more.
A steady stream of countries has announced steps towards implementing pillar two, but Korea has got there first. Ralph Cunningham finds out what tax executives should do next.
The BEPS Monitoring Group has found a rare point of agreement with business bodies advocating an EU-wide one-stop-shop for compliance under BEFIT.