International updates - November 2014

October 31 2014

The latest international updates from our correspondents around the world.

Albania: Transfer pricing: A step forward for Albania

Bosnia and Herzegovina: Changes to Law on Cash Registers in Republic of Srpska

Bulgaria: Bulgarian VAT Law amendments

Canada: Recent treaty shopping developments

Chile: New thin capitalisation rules

China: SAT’s formal assessment on service fees and royalty payments

Cyprus: Cyprus expands its treaty network with Lithuania and Guernsey

EU: Fiscal state aid and BEPS: EU Commission launches series of in-depth investigations into specific tax rulings and regimes

Germany: Self-disclosure rule amendments bring good and bad news for corporates

Hong Kong: Hong Kong commits to the Common Reporting Standard

India: Ruling on characterisation of surplus on sale of debentures

Ireland: Ireland ready for VAT Mini-One-Stop-Shop

Italy: Positive boost for special regime applicable to certain listed real estate investment companies

Luxembourg: Luxembourg signs new protocol to treaty with France

FYR Macedonia: New Profit Tax Law to enter into force in 2015

Montenegro: Montenegro-Azerbaijan DTT analysis

Serbia: Reactions to the application of FATCA regulations in Serbia

South Africa: Interest withholding tax update

Spain: Changes to the inbound expatriates system: Beckham clause attracts talent to Spain

Switzerland: Corporate tax reform as per draft legislation would make Switzerland more attractive for multinationals

US Inbound: IRS issues portfolio interest payment clarification

US Outbound: Treasury Department releases new anti-inversion rules

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Direct Tax

Merger international

Hogan Lovells, Cadwalader to merge in ‘largest combination in history’

A vote to be held in 2026 could create Hogan Lovells Cadwalader, a $3.6bn giant with 3,100 lawyers across the Americas, EMEA and Asia Pacific

Noemi Distefano, December 18 2025

Direct Tax

Libya

Whose tax is it anyway – Libya’s permanent establishment conundrum

Foreign companies operating in Libya face source-based taxation even without a local presence. Multinationals must understand compliance obligations, withholding risks, and treaty relief to avoid costly surprises

Salaheddin El Busefi , December 18 2025

Indirect Tax

HMRC scores Supreme Court VAT victory over Hotel La Tour

Hotel La Tour had argued that VAT should be recoverable as a result of proceeds being used for a taxable business activity

Sam Sholli, December 17 2025

Direct Tax

EY recruits provided AI training but still taught ‘old way’

Tax professionals are still going to be needed, but AI will make it easier than starting from zero, EY’s global tax disputes leader Luis Coronado tells ITR

Sam Sholli, December 17 2025

Direct Tax

KPMG reports 7.5% tax and legal services revenue increase

AI and assisting clients with navigating global tax reform contributed to the uptick in turnover, the firm said

Sam Sholli, December 16 2025

Direct Tax

scott bessent.jpg

US Treasury secretary eyes pillar two deal finalisation this week

In a post on X, Scott Bessent urged dissenting countries to the US/OECD side-by-side arrangement to ‘join the consensus’ to get a deal over the line

Tom Baker, December 16 2025

Direct Tax

Business deal mergers and acquisitions

Winston & Strawn and Taylor Wessing merger confirmed, new brand unveiled

A new transatlantic firm under the name of Winston Taylor is expected to go live in May 2026 with more than 1,400 lawyers and 20 offices

Noemi Distefano, December 15 2025

Direct Tax

Copy of What Corporates Want 2025.png

Italy’s opaque tax system underlies in-house discontent, advisers say

As ITR’s exclusive data uncovers in-house dissatisfaction with case management, advisers cite Italy’s arcane tax rules

Tom Baker, December 15 2025

Direct Tax

Horse racing

A taxing week: HMRC’s GfC13 puts tax advisers in an unwinnable situation

The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations

Tom Baker, December 12 2025

Direct Tax

Merger international

Taylor Wessing in merger talks with US firm Winston & Strawn

Taylor Wessing, whose most recent UK revenues were £283.7m, would become part of a £1.23bn firm post combination

Tom Baker, December 12 2025