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

Topics

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Transfer Pricing

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ITR spoke to two US TP experts about the long-running dispute, with one arguing that the case highlights ‘weaknesses’ with the comparable uncontrolled transaction method

Sam Sholli, September 18 2025

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Riyadh

A&M Tax continues rapid Asia expansion with Saudi Arabia launch

The new practice, which features former ‘big four’ experience, already has over 20 team members

Tom Baker, September 17 2025

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AI to transform tax profession, say in-house experts

Speakers from companies including Uber and Stripe told the inaugural AI in Tax Forum to brace for impending changes to how advisers work

Ed Conlon, September 17 2025

Direct Tax

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New Indian ruling on applying multilateral instruments and PPT provisions: analysis

Authors from Khaitan & Co dissect a ‘welcome’ ruling, which found that the mere existence of a tax benefit would not, by itself, warrant a principal purpose test

Sanjay Sanghvi, September 16 2025

Direct Tax

Big Ben and the Houses of Parliament at night in London, UK

Three-quarters of UK public support PCbCR: report

Over two-thirds of survey respondents back the continuation of the UK’s digital services tax, research commissioned by the Fair Tax Foundation also found

Tom Baker, September 15 2025

Direct Tax

Africa

A taxing week: The OECD must take developing countries seriously

Given the US/G7 pillar two deal, the OECD is in danger of being replaced by the UN as the leading global tax reform forum

Sam Sholli, September 12 2025

Direct Tax

This week in tax: PE house Cinven invests in Grant Thornton Germany

Cinven’s latest investment follows its acquisition of a stake in Grant Thornton UK in December; in other news, a barrister listed by HMRC as a tax avoidance promoter has alleged harassment

Tom Baker, September 12 2025

Direct Tax

OECD

Corporate income tax rate reductions slowing down: OECD report

CIT base narrowing measures remain more prevalent than increased CIT rates, the report also highlighted

Sam Sholli, September 11 2025

Direct Tax

Legal Benchmarking Group acquires The Lawyer

ITR's parent company, LBG, will acquire The Lawyer, a leading news, intelligence and data-driven insight provider for the legal industry, from Centaur Media

Ed Conlon, September 11 2025

Transfer Pricing

UK and Netherlands

Multilateral APAs in the UK and Netherlands: a history

KPMG UK’s Graeme Webster and KPMG Meijburg & Co’s Eduard Sporken outline the 20-year evolution of MAPAs, with DEMPE analyses becoming more prevalent and MAPA requirements growing stricter

Graeme Webster, September 11 2025