International updates - May 2014

April 30 2014

The latest international updates from our correspondents around the world.

Albania: VAT Reimbursement Procedure Directive

Australia: Australian offshore voluntary disclosure initiative 2014

Brazil: Attorney general of the National Treasury issues opinion so as to apply treaty provisions regarding the payment of service fees

Bulgaria: Bulgarian National Revenue Agency’s official position on reinvoicing of expenses

Canada: Canada’s 2014 budget eliminates tax benefits of immigration trusts

China: New foreign exchange policies on supporting the development of China (Shanghai) pilot free trade zone

Cyprus: Timeframes for registration of Cyprus international trusts

EU: Political agreement on new EU rules on PPLs/hybrid loans

Germany: Restrictive application of the German trust model

Hong Kong: TIEA signed with US

India: Indian government proposes revised version of Indian Tax Laws

Italy: New exchange of information rules implemented in Italy

FYR Macedonia: FYR Macedonia ratifies double tax treaty with Bosnia & Herzegovina

Malta: Malta’s recent efforts towards effective exchange of information

Mexico: Limitation on income tax deductions affecting international transactions

Montenegro: Witholding tax on dividends and its methodology

New Zealand: New Zealand’s Inland Revenue finalises interpretation statement on tax residence

Serbia: Determining the income tax for non-profit organisations in Serbia

South Africa: Tax dispute resolution

Spain: Government prepares sweeping tax reform

Switzerland: Revised guidance on the taxation of Swiss principal companies

Ukraine: Ukraine enacts a package of anti-crisis tax changes

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Indirect Tax

Brazil tax money

Advisers hope Brazil and US reach agreement on Trump tariffs

The threat of 50% tariffs on Brazilian goods coincides with new Brazilian legal powers to adopt retaliatory economic measures, local experts tell ITR

Sam Sholli, July 18 2025

Direct Tax

germany berlin reichstag building german parliament bundestag - Concept piece for power, authority, economy, performance, government, planning and control.

This week in tax: Germany still ‘committed’ to pillar two despite chancellor’s condemnation

The country’s chancellor appears to have backtracked from previous pillar two scepticism; in other news, Donald Trump threatened Russia with 100% tariffs

Tom Baker, July 18 2025

Direct Tax

OECD image.jpeg

OECD unveils pillar two safe harbour for highly taxed MNEs

In its latest G20 update, the OECD also revealed tense discussions with the US where the ‘significant threat’ of Section 899 was highlighted

Tom Baker, July 17 2025

Direct Tax

Big Ben at golden hour

Too many HMRC compliance investigations last too long, committee warns

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

Sam Sholli, July 17 2025

Transfer Pricing

UK TP proposals could ‘double compliance costs’, tax firm warns

Saffery cautioned that documentation requirements in new government proposals must be limited if medium-sized companies are not exempted from TP

Tom Baker, July 16 2025

Direct Tax

OECD image.jpeg

Pillar two no longer has a future, German chancellor claims

The global minimum tax deal is not viable without US participation, Friedrich Merz has argued

Sam Sholli, July 16 2025

Direct Tax

Pillar two is revising global tax competition with a 15% minimum tax rate

Future of pillar two uncertain after Section 899 withdrawal averts ‘catastrophe’

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

Ralph Cunningham, July 16 2025

Direct Tax

amory_heine resized.jpg

‘Pro bono is a must’: Amory Heine on giving back

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

July 15 2025

Direct Tax

Hillier, Craig_ColorPortrait.jpg

‘Huge, complex’ pillar two system encroaches on sovereignty: EY tax leader

Tax expert Craig Hillier agrees with the comparison of pillar two to using a sledgehammer to crack a nut

Sam Sholli, July 14 2025

Direct Tax

London- HM Revenue and Customs building on Whitehall, UK Governm

HMRC believes US companies underpaid £8.8bn in tax: accountancy group

The amount is reported to be up 57% from the £5.6bn that the UK tax agency believes was underpaid in the previous year

Sam Sholli, July 14 2025