International updates - November 2014

October 31 2014

The latest international updates from our correspondents around the world.

Albania: Transfer pricing: A step forward for Albania

Bosnia and Herzegovina: Changes to Law on Cash Registers in Republic of Srpska

Bulgaria: Bulgarian VAT Law amendments

Canada: Recent treaty shopping developments

Chile: New thin capitalisation rules

China: SAT’s formal assessment on service fees and royalty payments

Cyprus: Cyprus expands its treaty network with Lithuania and Guernsey

EU: Fiscal state aid and BEPS: EU Commission launches series of in-depth investigations into specific tax rulings and regimes

Germany: Self-disclosure rule amendments bring good and bad news for corporates

Hong Kong: Hong Kong commits to the Common Reporting Standard

India: Ruling on characterisation of surplus on sale of debentures

Ireland: Ireland ready for VAT Mini-One-Stop-Shop

Italy: Positive boost for special regime applicable to certain listed real estate investment companies

Luxembourg: Luxembourg signs new protocol to treaty with France

FYR Macedonia: New Profit Tax Law to enter into force in 2015

Montenegro: Montenegro-Azerbaijan DTT analysis

Serbia: Reactions to the application of FATCA regulations in Serbia

South Africa: Interest withholding tax update

Spain: Changes to the inbound expatriates system: Beckham clause attracts talent to Spain

Switzerland: Corporate tax reform as per draft legislation would make Switzerland more attractive for multinationals

US Inbound: IRS issues portfolio interest payment clarification

US Outbound: Treasury Department releases new anti-inversion rules

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New research, which suggests LLMs can silently corrupt complex documents, should alert tax and legal teams relying on AI to handle iterative drafting and compliance workflows

Marc Mokrab, July 10 2026

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PM-in-waiting Burnham unlikely to deviate from tax agent registration: experts

Maintaining increased funding for HMRC is a ‘high possibility’ if he becomes PM, ITR has also heard

Sam Sholli, July 09 2026

Awards

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ITR Europe Tax Awards 2026: shortlist announced

ITR is delighted to reveal all the shortlisted nominees for the 2026 Europe Tax Awards

John Harrison, July 09 2026

Direct Tax

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Charles Russell Speechlys enters US with private client splash

The firm has hired a team of private client lawyers from Withers to launch in New York and Connecticut, though ITR analysis suggests it faces stiff competition

Sam Sholli, July 08 2026

Direct Tax

‘Multiple versions of truth’: EY leader on in-house tax data challenges

The ability of tax authorities to receive and analyse data is becoming ‘quite advanced’, warns Stuart Lang, head of EY’s compliance co-sourcing solution

Sam Sholli, July 08 2026

Direct Tax

Royal Courts of Justice in London

Burlington v HMRC and the interpretation of double taxation treaty anti-avoidance clauses

The Court of Appeal ruling clarifies that treaty benefits are not abusive where transactions are commercially driven, providing greater certainty on “main purpose” anti-avoidance tests

Matthew Greene, July 07 2026

Transfer Pricing

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Beyond the headlines: Are TP software providers challenging tax advisory hegemony?

Despite the Netherlands featuring an unusual concentration of World Tax-ranked technology-led providers, sources believe there’s a long way to go to challenge the established players

Tom Baker, July 06 2026

Direct Tax

A taxing week: EY allegations suggest big four scandal at all levels

Ethics seems to be playing a subservient role to an entitlement culture borne out of a pervasive ‘revenue at all costs’ mentality at the big four

Sam Sholli, July 03 2026

Direct Tax

Hogan Lovells Cadwalader’s $3.6bn merger goes live

Historical World Tax data suggests the ‘largest law firm merger in history’ may not pose a serious threat to the world's leading tax practices

Noemi Distefano, July 02 2026

Direct Tax

Libya

Libyan tax disputes: choosing between settling and challenging

The repeal of Libya’s statute of limitations and tougher enforcement leave taxpayers navigating a high-stakes choice between conciliation and litigation

Salaheddin El Busefi , July 02 2026