April 2014

Main

The global harmonisation of exchange of information

Implications for maquiladoras of the 2014 Mexican tax reform

India: Profit attribution to permanent establishments

Operational TP: When tax function meets finance function

EU breakthrough on Savings Tax Directive

Bradbury to head OECD’s tax policy unit

Nelson joins Morgan Lewis in Boston

Aurélia de Viry launches King & Spalding’s French tax practice

Two tax barristers become QCs in UK

Baker & McKenzie recruits Clark from Heenan Blaikie

Rockwell Olivier hires Morris Maroon as head of tax

Bjørnholm leaves Hannes Snellman for Plesner

Fiszer joins GESSEL in Warsaw

Matthew Lerner joins Sidley Austin as tax controversy partner

Deals of the month

Saint-Amans defends OECD’s CRS despite loopholes identified by TJN

Obama and Camp plans show distance left to travel on US reform

Why Europe’s VAT system is taking time to achieve harmonisation

UK Budget: Welcome certainty for business as lobbying pays off

Semeta’s legacy: The Commissioner’s greatest achievements

Teamwork central to Telefônica’s tax compliance in Brazil

Europe’s plan for FTT fails to convince

Special features - April 2014

Albania: Albania changes its VAT legislation

Australia: Tax consolidation rules: Potential risk areas

Bosnia and Herzegovina: Tax Treaty between Bosnia & Herzegovina and Azerbaijan

Bulgaria: Constitutional Court revokes the unified account for tax payments

Canada: Extension of Canadian thin capitalisation rules announced

Chile: Tax treatment of capital reductions by the recipient entity

China: New China-France double tax agreement signed

Cyprus: Special defence contribution on dividends reverts to lower levels

EU: Update on the EU FTT

Hong Kong: Budget handed down

India: Delhi High Court rules on constitution of permanent establishment in outsourcing arrangements

Italy: Italy extends International Standard Ruling procedure

Luxembourg: VAT Update

FYR Macedonia: Reinstatement of withholding tax on dividends distributed to resident companies

Mexico: New mining and environmental royalties

Montenegro: Montenegro regulates taxation of hydrocarbon production activities

New Zealand: New Zealand enacts new laws relating to taxation of foreign superannuation interests

Serbia: Decree on conditions required for deferment of tax debt payment

South Africa: A modest Budget speech

Spain: Tax authorities disregard third-party’s remuneration by using secret comparables

Switzerland: Embracing the worldwide trend of increasing substance requirements

Switzerland : Itelcar: How Switzerland may benefit from Portuguese thin capitalisation rules

US Inbound: Obama Administration issues Green Book

Tax Relief

Malaysia: The road to GST implementation

International Correspondents

Features

New Analysis

Tax Relief

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