International updates - September 2014

Albania: VAT deferral for machinery and equipment imports in Albania

Brazil: Brazilian revenue authorities release provision for treating certain Swiss regimes as privileged tax regimes

Bulgaria: Prognosis for Bulgarian GDP growth

Canada: Canada signs protocol to amend Canada-UK tax treaty

Chile: Chilean tax reform – Where are we now? Proposed changes in light of international businesses and Chile’s tax treaties

China: Guidance on Chinese general anti-avoidance rule published for comment

Cyprus: Cyprus investment firm (CIF): A good vehicle into the European investment arena

EU: IP regimes under scrutiny in Europe

Germany: Has the ECJ opened the door to horizontal group relief?

Hong Kong: Hong Kong signs double tax agreement with South Korea

India: Ruling on availability of treaty benefits to a non-beneficial owner recipient

Italy: New direct lending opportunities in Italy

Luxembourg: Luxembourg tax authorities release circular on the use of a foreign functional currency for tax purposes

FYR Macedonia: FYR Macedonia abolishes the calendar year as a VAT period; aims to decrease VAT registration threshold

Malta: Budget 2014 implementation: Tax updates

Mexico: New tax position on pro-rata expenses assigned to Mexico

New Zealand: Tax policies to feature in general election

Poland: Polish thin cap rules to change

South Africa: New thin capitalisation rules

Spain: Changes to the Spanish participation exemption regime

Switzerland: Switzerland considering notional interest deduction on equity

Ukraine: Ukrainian government embarks on a tax offensive trying to boost collections

US Inbound: BEPS roundup: Developments and US views

US Outbound: IRS issues notice clarifying section 901(m) disposition rule