International updates - July/August 2015

July 14 2015

The latest international updates from our correspondents around the world.

Argentina: New Argentina-Chile tax treaty creates fresh structuring opportunities

Australia: Australian Budget measures receive royal assent

Bulgaria: The alternative choice for tax planning

Canada: CRA GAAR committee documents compelled – Superior Plus Corp v the Queen

Chile: Transitory regime for goods and income located or perceived abroad

Chile: New instructions regarding provisional withholding on capital gains

China: Implementation guidance issued for Announcement 7 indirect transfers

EU: ‘Tax Transparency Package 2.0’: New EU action plan for fundamental reforms of business taxation in the EU

Germany: Federal Tax Court rules CFC income is not subject to trade tax

Hong Kong: Hong Kong moves towards a favourable Treasury regime

Luxembourg: Luxembourg starts ratification process of four new tax treaties and six amending protocols

Malta: Aviation transactions benefit from Malta tax regime

Middle East: The impact of FATCA on financial institutions in the GCC

Montenegro: New incentive related to cinematography law in Montenegro

New Zealand: Government announces measures for taxing gains from sales of residential property

New Zealand: New director requirements and disclosure obligations for New Zealand companies

Poland: Changes to the Polish VAT law

Russia: New Russian transfer pricing rules for corresponding adjustments

Spain: Spain set to introduce modifications to transfer pricing reporting requirements

Switzerland: Revised draft legislation on Corporate Tax Reform III introduced into parliament

US Outbound: Final anti-inversion regulations retain bright-line substantial business activities test

Topics

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Transfer Pricing

‘Taxpayers are thrilled’: local experts hail record-breaking Indian APAs

Booming APA statistics reflect the growing credibility of India’s TP framework and the country’s shift toward a tax certainty approach, ITR has heard

Sam Sholli, April 16 2026

Direct Tax

Hogan Lovells Cadwalader merger approved, debut planned for July

Partners at both firms have voted in favour of the tie-up, which marks ‘the largest law firm merger in history’

Noemi Distefano, April 15 2026

Podcasts

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Podcast: Side-by-side or upside down? Analysing the future of pillar two

The latest edition of Taxing Times with ITR covers all the controversy from a dramatic period for the carve-out deal, and also dissects the big four's AI strategies

Tom Baker, April 15 2026

Direct Tax

Gulf Cooperation Council GCC

Rethinking permanent establishment in the GCC after pillar two

Hany Elnaggar examines how the OECD’s global minimum tax is reshaping PE concepts across the GCC, shifting the focus from formal presence to substantive economic activity

Hany Elnaggar, April 14 2026

Direct Tax

Merger international

Ashurst Perkins Coie moves forward with partners’ vote

The combination between Ashurst and Perkins Coie, which will create a $2.8 bn law firm, is expected to close in Q3

Noemi Distefano, April 13 2026

Transfer Pricing

norton rose fulbright

Norton Rose Fulbright hires new TP head from Baker McKenzie

The ‘highly regarded’ Stephanie Pantelidaki, who has big four experience, will be based in the firm’s London office

Sam Sholli, April 13 2026

Direct Tax

Newly-promoted Skadden UK partner talks TP, growth areas and HMRC collaboration

A co-operative working relationship with the UK tax agency has helped 'unblock entrenched positions' to the benefit of clients, Kara Heggs tells ITR

Sam Sholli, April 13 2026

Direct Tax

BDO

BDO planning to cut roughly 6% of partners in UK

New hires from rivals are reportedly being axed from the firm, following a steep decline in profits

Sam Sholli, April 10 2026

Direct Tax

Deloitte.jfif

A taxing week: Is Darren Graves the man to up Deloitte’s tax game?

Following Richard Houston’s switch to the newly formed Deloitte EMEA, Graves has the opportunity to bring Deloitte’s tax practice up to speed with its rivals

Sam Sholli, April 10 2026

Direct Tax

Cuatro Torres in Madrid

This week in tax: Dentons hires tax partner from DLA Piper in Madrid

Firms announced tax hires and promotions across Europe and the US, while fresh figures from Ireland showed corporation tax receipts edging down in the first quarter

Tom Baker, April 10 2026