International updates - December/January 2015

December 17 2014

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

Topics

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More from across our site

Transfer Pricing

Coca-cola

Is Coca-Cola’s ‘Black Swan’ event in sight?

As Coca-Cola awaits a crucial 11th Circuit Court of Appeals decision this year, its multibillion-dollar tax dispute could have profound implications for investors, cash flow, and corporate transparency

Alex Martin, March 10 2026

Direct Tax

Gender equality

Gender equality has improved ‘significantly’: 79% of female tax advisers

However, women in tax face greater career obstacles than their male counterparts, an exclusive ITR survey of more than 100 women tax leaders revealed

Tom Baker, March 09 2026

Direct Tax

jeff soar resized.jpg

Former EY tax leader spearheads WTS UK launch

Under Jeff Soar’s leadership, WTS UK aims to scale to 100 partners within five years and challenge the big four

Tom Baker, March 09 2026

Direct Tax

A taxing week: Deloitte’s culture is about to face a tough test

As the firm embarks on a major shakeup of its EMEA partnerships, some staff will be watching nervously

Ed Conlon, March 06 2026

Direct Tax

Close up shake hands, Considering buying a home, investing in real estate. Broker signs a sales agreement. agent, lease agreement, successful deal.

This week in tax: Ryan acquires property tax consulting firm in US

The buyout of Hucke and Associates continues Ryan’s streak of firm acquisitions; in other news, a UK appeal against VAT on private school fees was dismissed

Sam Sholli, March 06 2026

Direct Tax

Dubai

Iran conflict: UAE tax teams operating as usual despite disruption

Tax teams are responding to usual client demand in the region, albeit with increased working from home flexibility, local sources indicate

Tom Baker, March 05 2026

Indirect Tax

US tariffs

This month in indirect tax: Tariff refund delays may cost US taxpayers $700m per month

A 120-plus-day delay to refunds would cost taxpayers almost $3bn in additional interest, the Cato Institute warned; plus indirect tax updates from February

Sam Sholli, March 04 2026

Direct Tax

UK pound,money of United kingdom close up on white, Pound UK not

US pillar two side-by-side deal will cost UK £700m per year

The Office for Budget Responsibility’s pessimistic pillar two forecast accompanied the UK chancellor’s muted Spring Statement, dubbed ‘as dull as possible’ by one adviser

Tom Baker, March 03 2026

Direct Tax

Nobel prize

Creative destruction and digital tax: reflecting on the 2025 Nobel Prize

Digital tax reform is dissolving the old ‘temporal buffer’, forcing systems, institutions, and professionals to adapt as real-time reporting reshapes governance, capability, and compliance

Nitin Agarwal, March 03 2026

Podcasts

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Taxing Times: introducing ITR’s new monthly podcast

Our first instalment features analysis of Deloitte’s landmark EMEA merger, Donald Trump’s Supreme Court tariff showdown and Venezuela’s tax evolution

Tom Baker, March 02 2026