International updates - December/January 2016

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International updates - December/January 2016

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The latest international updates from our correspondents around the world.

Albania: Treaty analysis: Albania and Kosovo sign new double taxation agreement

Argentina: Argentina and Mexico sign double tax treaty

Australia: Tax reform topics continue to dominate political scene in Australia

Brazil: Update on the obligation to disclose certain transactions in Brazil

Bulgaria: Treaty analysis: Bulgaria and UK sign new double taxation agreement

Canada: Canadian Federal Court pulls the reins in (slightly) on foreign information requests

Chile: Applicability of the beneficial owner concept for dividends in Chile

Chile: Chilean IRS’s Anti-avoidance Bureau and the Administrative Consultation Procedure

Cyprus: Post-sanctions Iran: Exploring the Iranian market via Cyprus

EU: European Commission issues final decisions in Starbucks and Fiat state aid cases

Germany: Exemption to Germany’s change-in-ownership rules expanded

India: India continues to promote domestic business environment

Indonesia: Indonesia issues a draft Bill for national tax amnesty; plans to cut taxes

Ireland: Ireland confirms AT1 instruments treated as debt

Italy: Companies migrating to Italy: New ‘internationalisation’ decree introduces rules to determine assets and liabilities’ tax basis

FYR Macedonia: Treaty analysis: FYR Macedonia ratifies double taxation agreement with Vietnam

Malta: Malta concludes treaty with Curaçao

Middle East: New incentives for foreign corporations in Kuwait

Montenegro: New VAT exemption incentives in Montenegro

New Zealand: New Zealand introduces Bill to impose GST on cross-border services

Poland: VATable and non-VATable transactions in Poland – allocation of input VAT

Russia: Russian conduit companies – do your sub-holding companies have substance?

Serbia: Treaty analysis: Serbia and Norway double taxation agreement

Spain: Spain opens door to impose penalties on contrived acts or transactions

Switzerland: Switzerland is likely to remain a premier group financing location post-BEPS

Ukraine: Ukraine amends list of low-tax jurisdictions

US Inbound: US issues new guidance on allocation of income

more across site & shared bottom lb ros

More from across our site

Recent news of job cuts at EY is symptomatic of how the PwC controversy has tarnished the reputation of the entire ‘big four’
Experts reportedly discussed extending the safe harbour to 2027 to give countries more time to legislate; in other news, Baker McKenzie and Greenberg Traurig made senior tax hires
Awards
Submit your nominations to this year's WIBL Americas Awards by January 23
Recent changes in UK tax rules and cross-border requirements are generating high demand for specialist advice, according to MHA
Hany Elnaggar examines how Gulf Cooperation Council countries are internalising transfer pricing norms within evolving fiscal systems shaped by both Islamic and international influences
Where a TP study of comparables produces an arm’s-length range, and the taxpayer’s filed position is outside that range, HMRC will adjust to the median by default
EY, KPMG, Deloitte, and PwC have all seen a decrease in public sector contracts since the scandal – it is understood
Consoli, a tax partner at Brazilian law firm Martinelli Advogados, tells ITR about the importance of staying at the coalface and constantly learning
Despite legislative gridlock, international investors should be wary of legal precedents set by recent court rulings, which could substantially alter the Spanish tax environment
The new outfit, Ashurst Perkins Coie, will bring together around 3,000 lawyers across 23 countries
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