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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Indirect Tax

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Direct Tax

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Direct Tax

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Direct Tax

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Transfer Pricing

Africa

TP audits are moving upstream, but can African authorities keep pace?

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Direct Tax

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French tax authority leads way in AI adoption

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Direct Tax

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HMRC invites taxpayers to stress-test pillar two filings in ‘private beta’

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Direct Tax

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Pillar two a ‘box-ticking’ exercise, admits MNE tax head

Sucafina’s tax chief was speaking at the ITR Pillar 2 Forum in London alongside experts from HMRC and other organisations

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