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International updates - December 2018 / January 2019

The latest international updates from our correspondents around the world.

Brazil: Brazil clarifies tax treatment of international charter leasing payments

Canada: Beware of Canadian withholding tax and the breadth of the restrictive covenant rules

Chile: A new concept of deductible expenses

China: Individual Income Tax (IIT) Law draft implementation guidance released

European Union: EU tax transparency is here to stay

Georgia: Georgia announces new Customs Code

Germany: Profit-split considerations in TNMM solutions in a post-BEPS world

Hong Kong: Hong Kong’s new R&D regime is here

Ireland: ATAD implementation continues with the introduction of CFC rules and exit charge

Italy: Transfer pricing adjustments: VAT treatment

Kosovo: Kosovo ratifies tax treaty with Austria

Luxembourg: EU Council agrees on ‘quick fixes’ for intra-community transactions on goods and domestic VAT fraud

Mexico: Mexico court rules against taxpayer in transfer pricing case

New Zealand: New Zealand considers tax on digital services

Russia: Beneficial ownership concept in Russia: claiming treaty benefits becomes more complicated

Russia: Tax monitoring becomes popular in Russia

Serbia: Serbia-San Marino DTA enters into force

Spain: Should non-resident individuals pay taxes on their interest in non-resident companies owning real property in Spain?

Switzerland: New Swiss Principal Company and Swiss Finance Branch rulings to be phased out from January 1 2019