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

New reforms represent the most seismic shift in Canadian TP legislation since its enactment and a clear inflection point for MNEs, ITR has heard
Spain did not transpose EU VAT rules for SMEs or works of art; in other news, an increased VAT threshold came into force in South Africa
While the IBS incorporates taxable events previously covered by state and municipal taxes, its governance and operational logic represent a significant departure from the legacy model
The new office on the fourth floor of 4 More London will span 14,230 square feet, with the potential to expand to the first and second floors
MNEs now face a shift from modelling to execution as the side‑by‑side deal forces tax teams to upgrade systems, harmonise data, and prevent costly pillar two mismatches
As recent surveys suggest a disconnect between AI adoption and employee engagement, the big four risk digging themselves into a strategic hole
Almost three-quarters of surveyed tax professionals are concerned about inaccurate AI outputs; in other news, Dentons hired a partner from CMS to lead its Belgian tax team
Long-running, high-value and complex enquiries are a significant reason for HM Revenue and Customs’s increased TP yield, experts suggest
Landmark legal updates in India have led companies to prioritise specialised tax advisers over accountants, ITR has found
Brazil’s shift to a nationwide consumption tax is more than conceptual; it fundamentally transforms municipal revenue, enforcement, and administrative disputes
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