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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Direct Tax

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Matthew Gilleard, November 02 2026

Direct Tax

Deloitte dominates again at ITR Americas Tax Awards

It was also a memorable night for Galicia, KPMG, Skadden and Pinheiro Neto, all of which scooped major awards at a gala ceremony in New York

Sam Sholli, October 30 2026

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A taxing week: (Richard) Houston, do we have a problem?

The former Deloitte UK CEO earned a 45% raise in a year when 1,000 staff reportedly lost their jobs – and the pay gap is only getting bigger

Ed Conlon, October 30 2026

Direct Tax

New York Forum

New York tax heavyweight Weil to wind down

In a seminal development for big law, the 95-year-old firm is set to cease operations after a series of high-profile partner departures

Tom Baker, October 29 2026

Direct Tax

john healey uk chancellor

‘Not for UK plc’: Budget prompts sceptical response from tax advisers

UK Chancellor John Healey extended a VAT cut, suspended tariffs, increased a bank surcharge and vowed to increase funding for HMRC

Sam Sholli, October 28 2026

Transfer Pricing

kristine riisberg tp us 2026.jpg

TP ‘matters more than ever’ under pillar two: Deloitte leader

Kristine Riisberg warned that TP decisions can determine top-up tax exposure under pillar two, while global consensus over the rules remains unsettled

Tom Baker, October 28 2026

Direct Tax

AI regulation

When cyber law becomes tax law

Both Germany’s NIS2 and the EU AI Act now determine whether a tax function can meet its obligations – and both can make management personally accountable

Christian Ewel, October 28 2026

Indirect Tax

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EU General Court narrows VAT exemption for credit management in securitisations

Originators, loan purchasers and securitisation vehicles may need to revisit servicing agreements and pricing after a key judgment narrowed the VAT credit management exemption

Florent Trouiller, October 27 2026

Ricardo Perera.jpg

Beyond the headlines: Why Baker McKenzie’s new tax disputes partner prefers nurturing talent to recruitment

Opening doors for existing talent within Baker McKenzie and a desire for enhanced legal capabilities informed Ricardo Perera’s switch from KPMG

Sam Sholli, October 26 2026