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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As recent surveys suggest a disconnect between AI adoption and employee engagement, the big four risk digging themselves into a strategic hole

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Brazil’s tax reform: how the IBS impacts municipalities

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While pillar two has been enacted on paper in Brazil, companies are encountering a range of practical compliance issues, ITR has heard

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Guinevere Moore on balancing tax litigation with childcare and ‘paying it forward’

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Clients considering US relocation following pillar two carve-out deal: Baker McKenzie

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