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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Pillar two is revising global tax competition with a 15% minimum tax rate

A taxing week: Pillar two will prosper despite US side-by-side arrangement

The political optics of the US’s carve-out deal are poor, but as the Fair Tax Foundation’s Paul Monaghan writes, it preserves pillar two’s guiding ethos

Paul Monaghan, February 27 2026

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This week in tax: PwC commences legal battle with boutique consultancy founded by ex-COO

The big four firm reportedly sent ‘threatening’ correspondence to Unity Advisory over its hiring of ex-PwC partners; plus tax recruitment news from the week

Sam Sholli, February 27 2026

Direct Tax

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Ex-US Supreme Court advocate convicted on 12 counts in tax trial

Tom Goldstein, who was represented by US law firm Munger, Tolles & Olson, denied wilfully cheating on his taxes and blamed errors on his staff

Sam Sholli, February 26 2026

Transfer Pricing

Suited figure pointing to audit among various hexagonal icons

TP documentation in a fragmented world: how to limit audit triggers

Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions

Daniel Moalusi, February 26 2026

Direct Tax

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‘Tax at breaking point’: Thomson Reuters’ AI tech hits one million users

The profession is fundamentally restructuring itself around what tax and accounting work should be, a Thomson Reuters leader told ITR

Sam Sholli, February 24 2026

Direct Tax

Deloitte unveils €20bn EMEA combination

The big four firm is consolidating 16 entities across the region to create a single 6,000-partner behemoth

Tom Baker, February 24 2026

Indirect Tax

The IBS and why it changes everything in Brazil’s consumption tax system

Brazil’s tax reform unifies consumption taxes to simplify rules, centralise administration and reduce legal uncertainty

Wesley Fragas, February 24 2026

Direct Tax

A&M Tax launches dedicated pillar two, TP team in Saudi Arabia

The ever-expansive firm has once again attracted a former ‘big four’ talent to lead the new offering

Tom Baker, February 23 2026

Direct Tax

France India

India and France sign updated tax treaty in ‘significant development’

The amended double taxation avoidance agreement removes France’s most favoured nation status for tax treaty benefits

Sam Sholli, February 23 2026

Indirect Tax

US tariffs

‘Refunds likely to be a mess’: US Supreme Court strikes down Trump’s tariffs

The levies extended beyond the president’s ‘legitimate reach’, the Supreme Court ruled

Sam Sholli, February 20 2026