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

The threat of 50% tariffs on Brazilian goods coincides with new Brazilian legal powers to adopt retaliatory economic measures, local experts tell ITR
The country’s chancellor appears to have backtracked from previous pillar two scepticism; in other news, Donald Trump threatened Russia with 100% tariffs
In its latest G20 update, the OECD also revealed tense discussions with the US where the ‘significant threat’ of Section 899 was highlighted
The tax agency has increased compliance yield from wealthy individuals but cannot identify how much tax is paid by UK billionaires, the committee also claimed
Saffery cautioned that documentation requirements in new government proposals must be limited if medium-sized companies are not exempted from TP
The global minimum tax deal is not viable without US participation, Friedrich Merz has argued
Section 899 of the ‘one big beautiful’ bill would have spelled disaster for many international investors into the US, but following its shelving, attention turns to the fate of the OECD’s pillars
DLA Piper’s co-head of tax for the US and Latin America tells ITR about her fervent belief in equal access to the law, loving yoga, and paternal inspirations
Tax expert Craig Hillier agrees with the comparison of pillar two to using a sledgehammer to crack a nut
The amount is reported to be up 57% from the £5.6bn that the UK tax agency believes was underpaid in the previous year
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