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

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While some advisers praised the ruling’s definition of a ‘voucher’ for VAT purposes, a UK partner said the case left unanswered questions
While pillar two has been enacted on paper in Brazil, companies are encountering a range of practical compliance issues, ITR has heard
Moore, founding partner of the Chicago tax boutique which bears her name, shares her career wisdom for ITR’s new Women in Tax interview series
But partners at the firm admit that jumping ship to the US would not be as easy as some believe
Governments are rewriting tax policy for the AI era, deploying digital taxes, tailored incentives and algorithmic enforcement that redefine where value is created
Wingrove will succeed Bill Thomas, who has served in the role since 2017; in other news, Andersen unveiled a sharp increase in revenues for 2025
Partners are divided on Italy vs PDM D’s analytical depth, evidentiary standards, and what the judgment signals for future intra-group financing cases
As GCCs increasingly become strategic hubs, multinationals face heightened risks around permanent establishment and place of effective management
While all options presented ‘drawbacks’, European Commission tax leader Wopke Hoekstra said the controversial US carve-out deal has ‘many benefits’
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