International updates - September 2014

August 31 2014

The latest international updates from our correspondents around the world.

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

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Direct Tax

Merger international

Hogan Lovells, Cadwalader to merge in ‘largest combination in history’

A vote to be held in 2026 could create Hogan Lovells Cadwalader, a $3.6bn giant with 3,100 lawyers across the Americas, EMEA and Asia Pacific

Noemi Distefano, December 18 2025

Direct Tax

Libya

Whose tax is it anyway – Libya’s permanent establishment conundrum

Foreign companies operating in Libya face source-based taxation even without a local presence. Multinationals must understand compliance obligations, withholding risks, and treaty relief to avoid costly surprises

Salaheddin El Busefi , December 18 2025

Indirect Tax

HMRC scores Supreme Court VAT victory over Hotel La Tour

Hotel La Tour had argued that VAT should be recoverable as a result of proceeds being used for a taxable business activity

Sam Sholli, December 17 2025

Direct Tax

EY recruits provided AI training but still taught ‘old way’

Tax professionals are still going to be needed, but AI will make it easier than starting from zero, EY’s global tax disputes leader Luis Coronado tells ITR

Sam Sholli, December 17 2025

Direct Tax

KPMG reports 7.5% tax and legal services revenue increase

AI and assisting clients with navigating global tax reform contributed to the uptick in turnover, the firm said

Sam Sholli, December 16 2025

Direct Tax

scott bessent.jpg

US Treasury secretary eyes pillar two deal finalisation this week

In a post on X, Scott Bessent urged dissenting countries to the US/OECD side-by-side arrangement to ‘join the consensus’ to get a deal over the line

Tom Baker, December 16 2025

Direct Tax

Business deal mergers and acquisitions

Winston & Strawn and Taylor Wessing merger confirmed, new brand unveiled

A new transatlantic firm under the name of Winston Taylor is expected to go live in May 2026 with more than 1,400 lawyers and 20 offices

Noemi Distefano, December 15 2025

Direct Tax

Copy of What Corporates Want 2025.png

Italy’s opaque tax system underlies in-house discontent, advisers say

As ITR’s exclusive data uncovers in-house dissatisfaction with case management, advisers cite Italy’s arcane tax rules

Tom Baker, December 15 2025

Direct Tax

Horse racing

A taxing week: HMRC’s GfC13 puts tax advisers in an unwinnable situation

The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations

Tom Baker, December 12 2025

Direct Tax

Merger international

Taylor Wessing in merger talks with US firm Winston & Strawn

Taylor Wessing, whose most recent UK revenues were £283.7m, would become part of a £1.23bn firm post combination

Tom Baker, December 12 2025