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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TP in Peru: where global profitability policies meet a transaction-by-transaction regime

Peru’s approach to TP is increasingly at odds with OECD-style profitability policies, exposing multinational groups to asymmetric tax adjustments

Miguel Puga, August 06 2026

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How ESR and pillar two are converging across the GCC

Hany Elnaggar examines how the region's legacy economic substance regimes and the OECD's pillar two framework are converging on the same underlying test

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Alphatax broadens TP portfolio with double acquisition

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From advisory to advocacy: why Gunjan Prabhakaran chose litigation

The DS Advocates partner discusses career reinvention, tax disputes and why advisory and litigation experience should complement one another

Tom Baker, August 04 2026

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Beyond the headlines: How ex-government talent strengthens top tax practices

Lindsay Clayton’s arrival at Baker McKenzie continues the firm’s storied pursuit of ex-US government lawyers, a strategy reinforced by robust World Tax rankings

Sam Sholli, August 03 2026

Indirect Tax

e-invoicing

Why Peppol is the right strategic choice for UK e-invoicing

Shared transaction semantics, governed data and reusable ERP design may prove the most significant benefits of the UK's move to Peppol

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Direct Tax

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A taxing week: Could this be the new UK PM’s most important decision?

As pillar two reshapes global tax competition, the UK faces a crucial challenge: how to remain attractive to multinationals without sacrificing tax revenues

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Direct Tax

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Pillar two has eroded but not imploded: tax academic

Pillar two may be raising less than expected, but professor René Matteotti says the regime is still changing multinational tax behaviour

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Brazil customs shipping

Brazil’s new customs valuation tools: TP documentation becomes harder to ignore

Multinationals importing goods into Brazil may need to align TP files and customs documentation more closely as authorities gain new tools to challenge related-party transactions

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