International updates - October 2014

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International updates - October 2014

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The latest international updates from our correspondents around the world.

Bosnia and Herzegovina: Excise law amended in Bosnia and Herzegovina

Brazil: New divergent decisions regarding taxation of merger of shares

Bulgaria: Amendments to the Bulgarian Public Procurement Act

Canada: Amendments to Canadian international tax proposals

Chile: Final approval for Chilean tax reform package expected next month

China: Notice on further strengthening corporate tax collection and administration on equity transfer

Cyprus: Double taxation agreement between Cyprus and Switzerland

EU FTT: End of the beginning, or beginning of the end?

Germany: Loss relief deferral unconstitutional?

Greece: Challenges in preparing Greek transfer pricing documentation

Hong Kong: Corporate residence determines source of director’s fees

India: Ruling on taxation of indirect transfer

Italy: New tax incentives for cultural activities and tourism sectors

Luxembourg: Recent tax treaties and protocols ratified by Luxembourg

FYR Macedonia: FYR Macedonia adds new product categories to the preferential VAT rate regime

Malta:Malta clarifies taxation of fees paid to non-resident investment committee members

Mexico: New miscellaneous rules introduce additional flexibility on the Mexican maquila regime

New Zealand: High Court rules on residency test for individuals

Poland: Proposal of amendments to VAT Act intended to fight fiscal frauds

Romania: Capital gains tax reporting

Serbia: Serbia – Armenia treaty ratified by Serbian parliament

South Africa: Tax exposure in respect of derivative income earned by non-residents

Switzerland: Swiss non-financial entities and new bank forms – everyone must tick a box

Ukraine: Ukraine tightens currency control rules

US Inbound: Inbound debt limitations

US Outbound: US Tax Court holds EC fine non-deductible under section 162(f)

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