International updates - March 2016

Albania: Albania and Morocco sign tax treaty

Brazil: Brazilian Federal Revenue Agency publishes tax decision on contribution of know-how into capital

Brazil: Brazil introduces regularisation programme for certain assets held abroad

Canada: Canadian voluntary disclosure programme rises in popularity

Chile: Chile’s new (not-so-)thin capitalisation rules

China: China’s 150% super deduction regulation

Cyprus: Reduced withholding tax rate on dividends from Russia to Cyprus

Georgia: Cyprus – Georgia tax treaty enters into force

Germany: German Federal Tax Court questions constitutionality of interest deduction limitation rule

Indonesia: Indonesia updates Asian treaty network; issues foreign customers’ exchange of information for financial institutions

Italy: Italy enhances IP regime and introduces grandfathering period for trademarks

Luxembourg: Luxembourg and the new face of the Russian tax realm

FYR Macedonia: FYR Macedonia and Israel sign tax treaty

Malta: Malta publishes Common Reporting Standard guidelines

Montenegro: Montenegro’s tax treatment of foreign corporate executives

New Zealand: New Zealand continues tax administration reform

Norway: Foreign rig owner wins Norway Supreme Court case concerning limited tax liability

Poland: Poland introduces new R&D tax incentives

Serbia: Serbia signs 66th double tax treaty

Spain: Control of state aid in Canary Islands investments

Switzerland: Swiss securities transfer tax – No new treatment for Swiss fund managers

Turkey: Constitutionality of the Turkish withholding tax rules: new decision, old school approaches and still a lack of legality

US Inbound: US revises treaty model

US Outbound: US issues proposed CbCR regulations