International updates - December/January 2015

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International updates - December/January 2015

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The latest international updates from our correspondents around the world.

Bosnia and Herzegovina: Special solidarity contribution entered into force in Bosnia and Herzegovina

Brazil: Brazilian Federal Revenue Authorities issue Normative Instruction regulating the tax treatment of dividends, interest on net equity and the equity-pick up method

Bulgaria: Bulgaria – Norway double tax treaty

Canada: Revised rules regarding back-to-back lending arrangements

Chile: New CFC rules

China: Clarification of tax position of Shanghai-Hong Kong Stock Connect programme and QFIIs/RQFIIs

Cyprus: Public listed companies in Cyprus

Germany: Treaty override under constitutional attack again

Hong Kong: Hong Kong signs Model 2 IGA under FATCA

India: Ruling on applicability of deduction non-discrimination clause

Ireland: Changes to Irish corporate residence rules

Italy: Italy announces Patent Box regime from 2015

Luxembourg: Tax measures to be introduced January 2015

FYR Macedonia Lower VAT registration threshold enacted; possibility of electronic invoicing introduced

Malta: Budget 2015: New and revised tax measures

Mexico: New miscellaneous rules allow the deduction of pro-rata expenses

Montenegro: Privatisation of Poliex: Montenegrin arms exporter

New Zealand: NZ Inland Revenue releases GAAR guidance

Norway: Corporate tax changes in the 2015 national Budget

Poland: Amendments to transfer pricing regulations from January 2015

Romania: Tax incentives introduced in 2014

Serbia: Controversial law on public notaries

South Africa: Treaty shopping in a South African context

Spain: Spanish Supreme Court confirms PE interpretation in certain business restructurings

Switzerland: Why the Swiss Corporate Tax Reform III needs to be aligned with BEPS

US Inbound: Inbound § 7874 issues

US Outbound: IRS releases final GRA regulations

more across site & shared bottom lb ros

More from across our site

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The plan aims to improve the efficiency, transparency, and effectiveness of direct tax administration in India
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Jaime Carey speaks about the benefits of his tax background, DEI values, the use of AI for a smarter legal practice, and other priorities that will define his presidency
Historically low levels of attrition over consecutive years made a ‘difficult decision’ necessary, PwC has reportedly said
WTS Global is also vetting new potential member firms in Algeria, Cote D’Ivoire and Benin, Kelly Mgbor tells ITR in an exclusive interview
The scope of qualifying pillar two tax credits could reportedly be broadened; in other news, hundreds of IRS appeals staff are to resign
For many taxpayers, the prospect of long-term certainty that a bilateral APA offers can override concerns about time, cost and confidentiality
Levine, who served under the Joe Biden administration, led the US’s negotiations on the OECD’s two-pillar solution
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