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International updates - March 2015


The latest international updates from our correspondents around the world.

Australia: Recent court case roundup; Structural reform delayed

Brazil: Increase of PIS and COFINS rates on the importation of goods

Canada: Heads I win, tails you lose: Canada Revenue Agency refuses to refund overpaid tax after statutory limitation periods expire

Chile: Tax credit regarding Chilean sourced income subject to withholding tax in a foreign jurisdiction

China: New regulations to encourage corporate restructuring and investment with non-monetary assets

EU: Update on patent boxes and the EU Code of Conduct Group (Business Taxation)

Germany: Deduction of foreign partner’s interest expense

India: Creation of service PE by activities of employees deputed to India

Ireland: ICAV – Ireland’s new corporate funds vehicle

Italy: New decree extends Patent Box regime to commercial trademarks and introduces tax measures for “indirect lending”

Luxembourg: Luxembourg tax authorities clarify the tax treatment of limited partnerships

Malta: Changes to VAT rules – Telecommunications, broadcasting and electronic services

Mexico: Mexican taxpayers’ advocacy institution issues recommendation on Mexican tax authorities’ requests for notarisation of private documents

Poland: Changes to the Polish corporate income tax law

South Africa: Base erosion and profit shifting – Debt:equity

South Korea: Korean courts narrowly interpret mitigating circumstances for non-compliance with FTA requirements

Spain: Invest not just into, but also from, the Canary Islands

Sweden: US investment funds exempt from Swedish dividend withholding tax under EU law – Swedish Tax Agency decides to not appeal ruling

Switzerland: How Swiss companies should apply the income tests for FATCA classification purposes

US Inbound: Obama releases FY 2016 Budget

more across site & bottom lb ros

More from across our site

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.
Former PwC partner Peter-John Collins has been banned from serving as a tax agent in Australia, while Brazil reports its best-ever year of tax collection on record.
Industry groups are concerned about the shift away from the ALP towards formulary apportionment as part of a common consolidated corporate tax base across the EU.
The former tax official in Italy will take up her post in April.
With marked economic disruption matched by a frenetic rate of regulatory upheaval, ITR partnered with Asia’s leading legal minds to navigate the continent’s growing complexity.
Lawmakers seem more reticent than ever to make ambitious tax proposals since the disastrous ‘mini-budget’ last September, but the country needs serious change.
The panel, the only one dedicated to tax at the World Economic Forum, comprised government ministers and other officials.
Colombian Finance Minister José Antonio Ocampo announced preparations for a Latin American tax summit, while the potentially ‘dangerous’ Inflation Reduction Act has come under fire.
The OECD’s two-pillar solution may increase global tax revenue gains by more than $200 billion a year, but pillar one is the key to such gains due to its fundamental changes to taxing rights.
The solution to address the tax challenges arising from digitalisation and globalisation will generate more revenue than previously estimated.