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

Topics

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Direct Tax

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‘Not for UK plc’: Budget prompts sceptical response from tax advisers

UK Chancellor John Healey extended a VAT cut, suspended tariffs, increased a bank surcharge and vowed to increase funding for HMRC

Sam Sholli, October 28 2026

Transfer Pricing

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TP ‘matters more than ever’ under pillar two: Deloitte leader

Kristine Riisberg warned that TP decisions can determine top-up tax exposure under pillar two, while global consensus over the rules remains unsettled

Tom Baker, October 28 2026

Direct Tax

AI regulation

When cyber law becomes tax law

Both Germany’s NIS2 and the EU AI Act now determine whether a tax function can meet its obligations – and both can make management personally accountable

Christian Ewel, October 28 2026

Indirect Tax

European,Currency,Symbol,Euro,With,Green,Up,Arrow,On,Sticky

EU General Court narrows VAT exemption for credit management in securitisations

Originators, loan purchasers and securitisation vehicles may need to revisit servicing agreements and pricing after a key judgment narrowed the VAT credit management exemption

Florent Trouiller, October 27 2026

Ricardo Perera.jpg

Beyond the headlines: Why Baker McKenzie’s new tax disputes partner prefers nurturing talent to recruitment

Opening doors for existing talent within Baker McKenzie and a desire for enhanced legal capabilities informed Ricardo Perera’s switch from KPMG

Sam Sholli, October 26 2026

Direct Tax

London

Exclusive: EY UK’s tax litigation head to join WTS UK

Boaz Goren’s move to the upstart PE-backed firm takes the number of senior UK tax professionals who have left EY this year to 13

Tom Baker, October 23 2026

Direct Tax

Deloitte.jfif

A taxing week: Deloitte should not hide behind its network amid Abramovich allegations

The allegations against Deloitte Cyprus raise uncomfortable questions about how far the big four can distance themselves from misconduct at member firms

Tom Baker, October 23 2026

Rankings analysis

World Tax middle east rankings release article 2026 image

World Tax Rankings Middle East 2027 released: challenger firms surge in UAE

The UAE accounted for most Middle East promotions and new rankings, as A&M Tax, Baker McKenzie, Dhruva Consultants and DLA Piper breached the top tier

Tom Baker, October 22 2026

Direct Tax

Fair Tax Mark

Exclusive: Weak pCbCR filings persist as Fair Tax Foundation analysis hits 650

Spanish-headquartered multinationals lead on reporting quality, while US and Swiss groups lag in the Fair Tax Foundation’s expanded analysis

Tom Baker, October 21 2026

Podcasts

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Podcast: Danny Werfel on AI risk, IRS leadership, and global tax cooperation

Former IRS commissioner Danny Werfel joins ITR for a must-listen conversation spanning his time leading the agency, his AI risk framework, and the future of the OECD

Tom Baker, October 21 2026