International updates - December/January 2015
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International updates - December/January 2015


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 & bottom lb ros

More from across our site

The full list of finalists has been revealed and the winners will be presented on June 20 at the Metropolitan Club in New York
The ‘big four’ firm has threatened to legally pursue those behind the letter, which has been circulating on social media
The guidelines have been established in the wake of multiple tax scandals and controversies that have rocked the accounting profession
KPMG Netherlands’ former head of assurance also received a permanent bar and $150,000 fine; in other news, asset management firm BlackRock lost a $13.5bn UK tax appeal
The new, fully integrated office will also offer M&A, dispute resolution, IP and corporate tax services
The new guidance concerns a recent 1% excise tax on the repurchases of corporate stock for both US and certain foreign companies
Interpath has hired a managing partner from rival accounting firm BDO to lead the new operation
Survey results of over 28,000 in-house lawyers reveal that American in-house counsel place a higher value on the reputation of external advisers than their peers elsewhere
In an exclusive interview with ITR, Andrew Leigh also endorsed new legislation designed to prevent multinationals using complex corporate structures to reduce taxes
Nick Crama and Parwesh Bissumbhar, senior director and manager respectively at Alvarez & Marsal, outline practical advice for real estate managers to comply with DAC6 regulations
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