International updates - October 2015

October 07 2015

The latest international updates from our correspondents around the world.

Albania: New tax incentives for operating in free zones in Albania

Australia: Multinational entity (MNE) anti-avoidance Bill introduced

Bosnia and Herzegovina: Bosnia and Herzegovina’s Corporate Income Tax Bill under review

Brazil: Provisional Measure 685/2015 extended for another 60-day period

Canada: Filing deadline approaching for Canadian foreign affiliate dumping rules

Chile: Withholding tax, treaties and provision of PE certificates

Cyprus: Ship management companies in Cyprus: An option worth considering

Germany: Retroactive changes to RETT rules to apply from 2009

India: Applicability of MAT to foreign investors

Ireland: Irish Revenue Commissioners issue guidance on the VAT treatment of portfolio management services in wake of Deutsche Bank

Luxembourg: Luxembourg amends participation exemption regime

FYR Macedonia: FYR Macedonia extends application of preferential VAT rate to first sale of residential buildings

Malta: Amendment to the highly qualified persons rules

Middle East: PE formation in KSA: Operating across borders

New Zealand: New Zealand proposes new GST rules for supplies of cross-border services

Poland: Amendments made to Polish property tax regime

Serbia: Amendments to the Serbian Excise Duties Act

South Korea: Proposed tax law amendments in 2015

Spain: Spain takes the lead as tax changes reflect economic upturn

Switzerland: Spontaneous exchange of tax rulings

Turkey: Transfer pricing of intra-group services with a special focus on recharacterisation as know-how

US Inbound: IRS international practice units

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Direct Tax

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Direct Tax

India Supreme Court

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India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist

Ravish Bhatt, April 28 2026

Direct Tax

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Unity Advisory appoints AI chief as firm hits 100 employees

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Direct Tax

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Indirect Tax

Prison

This week in tax: HMRC jails payroll fraudsters for 22 years

HMRC secured lengthy prison sentences in a major payroll VAT fraud case, while law firms announced tax promotions and hires

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Transfer Pricing

Australian Company Tax Return concept

‘More refined’: advisers dissect updated ATO TP guidance

Significant changes include an update to profit markers and an alteration to how an ‘inbound distributor’ is defined

Sam Sholli, April 23 2026

Direct Tax

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Direct Tax

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Brazil has ‘substantive grounds’ for pillar two carve-out request: advisers

Brazil’s bid to seek US-style exemptions from pillar two is ‘highly advantageous’ for multinationals, ITR has also heard

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