March 2015

Main

Negative harmonisation: The EC, goodwill and state aid

Reform of the US tax system: Searching for the magic key

The digital economy: Indirect tax and e-services

Gulliver’s travails

The Brockman brief: Interest: Double taxation equality is fading

Deals of the month

Businesses say Obama proposals will harm economic growth

OECD looking for a way forward on arbitration

Foreign companies could be caught in China’s new indirect transfer rules

Keeping track of a shifting transfer pricing landscape

Navigating NZ treatment of cross-border service supplies

Special features - March 2015

Australia: Recent court case roundup; Structural reform delayed

Brazil: Increase of PIS and COFINS rates on the importation of goods

Canada: Heads I win, tails you lose: Canada Revenue Agency refuses to refund overpaid tax after statutory limitation periods expire

Chile: Tax credit regarding Chilean sourced income subject to withholding tax in a foreign jurisdiction

China: New regulations to encourage corporate restructuring and investment with non-monetary assets

EU: Update on patent boxes and the EU Code of Conduct Group (Business Taxation)

Germany: Deduction of foreign partner’s interest expense

India: Creation of service PE by activities of employees deputed to India

Ireland: ICAV – Ireland’s new corporate funds vehicle

Italy: New decree extends Patent Box regime to commercial trademarks and introduces tax measures for “indirect lending”

Luxembourg: Luxembourg tax authorities clarify the tax treatment of limited partnerships

Malta: Changes to VAT rules – Telecommunications, broadcasting and electronic services

Mexico: Mexican taxpayers’ advocacy institution issues recommendation on Mexican tax authorities’ requests for notarisation of private documents

Poland: Changes to the Polish corporate income tax law

South Africa: Base erosion and profit shifting – Debt:equity

South Korea: Korean courts narrowly interpret mitigating circumstances for non-compliance with FTA requirements

Spain: Invest not just into, but also from, the Canary Islands

Sweden: US investment funds exempt from Swedish dividend withholding tax under EU law – Swedish Tax Agency decides to not appeal ruling

Switzerland: How Swiss companies should apply the income tests for FATCA classification purposes

US Inbound: Obama releases FY 2016 Budget

UK tax code – does size matter?

Messi blames tax case for poor form

Findlay takes Golden Scissors to red tape in Canadian tax code

Quotes of the month

Cheers! Celebrate the world's top transactional firms

International Correspondents

Features

New Analysis

Tax Relief

Special Features

Editorial

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