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)

more across site & shared bottom lb ros

More from across our site

The Australian Taxation Office believes the Swedish furniture company has used TP to evade paying tax it owes
Supermarket chain Morrisons is facing a £17 million ($23 million) tax bill; in other news, Donald Trump has cut proposed tariffs
The controversial deal will allow US-parented groups to be carved out from key aspects of pillar two
Awards
ITR invites tax firms, in-house teams, and tax professionals to make submissions for the 2027 World Tax rankings and the 2026 ITR Tax Awards globally
Pillar two was ‘weakened’ when it altered from a multinational convention agreement to simply national domestic law, Federico Bertocchi also argued
Imposing the tax on virtual assets is a measure that appears to have no legal, economic or statistical basis, one expert told ITR
The EU has seemingly capitulated to the US’s ‘side-by-side’ demands. This may be a win for the US, but the uncertainty has only just begun for pillar two
The £7.4m buyout marks MHA’s latest acquisition since listing on the London Stock Exchange earlier this year
ITR’s most prolific stories of the year charted public pillar two spats, the continued fallout from the PwC Australia tax leaks scandal, and a headline tax fraud trial
The climbdowns pave the way for a side-by-side deal to be concluded this week, as per the US Treasury secretary’s expectation; in other news, Taft added a 10-partner tax team
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