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

KordaMentha launches tax disputes practice with ATO, PwC Australia hires

Among the arrivals is Andrew Howell, who leaves scandal-hit PwC Australia after representing PepsiCo in a high-profile TP dispute

Sam Sholli, July 22 2026

Podcasts

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Podcast: What the KPMG Australia scandal means for the big four

ITR's podcast examines whether the big four have overarching cultural issues and assesses the competitive threat of technology-backed transfer pricing firms

Tom Baker, July 22 2026

Direct Tax

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MHA records 12% revenue rise a year on from London IPO

The UK advisory firm has seen its global revenues expand by £27.2m following its listing and acquisition of Baker Tilly South-East Europe

Sam Sholli, July 21 2026

Direct Tax

Michael Ebeid and John Sams, KPMG

KPMG Australia’s new CEO vows to improve culture following scandal

Tax-trained John Sams, previously the firm’s CFO and COO, was appointed after a rigorous process, KPMG said

Tom Baker, July 21 2026

Transfer Pricing

Intellectual property Africa

Pay attention to tax when taking IP across borders in Africa

From Mauritius substance rules to Kenyan SEP tax and South African anti-avoidance measures, businesses must navigate growing scrutiny of cross-border IP structures in Africa

The tax team at Bowmans, July 21 2026

Direct Tax

Global digital

Beyond the headlines: Lessons from pillar two’s first and farcical filing deadline

ITR spoke to multinationals, advisers and software providers about a June 30 deadline defined by faulty portals, high compliance costs and hard lessons

Tom Baker, July 20 2026

Direct Tax

Compliance frustration onerous pillar two

A taxing week: Pillar two revenue shortfall a gut-punch for MNEs

After years of onerous pillar two prep, businesses will be galled in seeing tax revenues outweighed by compliance costs

Tom Baker, July 17 2026

Direct Tax

The EY US dispute: why secondment structures need fresh Indian review

Tax advisers should revisit India secondment arrangements after the EY US ruling strengthened the Centrica precedent and raised fresh withholding concerns

Aditi Goyal, July 16 2026

Direct Tax

OECD

Pillar two revenues lower than anticipated, OECD admits

Despite the shortfall, effective tax rates of multinationals have seen a ‘statistically significant rise’

Sam Sholli, July 15 2026

Direct Tax

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Behind the hire: Stuart Alter on developing Milbank’s fund formation practice

After joining Milbank from Akin Gump, the fund tax specialist discusses sponsor demand, practice building, and the tax challenges facing asset managers

Tom Baker, July 15 2026