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September 2013
Main
Mixed messages and core conflicts
Baker & McKenzie promotes 15 to tax partner
Scheine and Gartner leave Kaye Scholer
IRS Chief of Appeals returning to Sutherland
Dechert partner appointed chair of ABA tax section
Edmund Leow steps up to Supreme Court in Singapore
KPMG UK shakes up tax litigation practice
Jerald Wortsman joins Torys
Two join Minter Ellison in Hong Kong to launch regional practice
Deals of the month
Germany wants European patent box regimes withdrawn
Why ECJ’s Argenta ruling benefits companies with loss-making PEs
Article 8 of the OECD Model lags behind international business
Multistate US tax issues for inbound companies
The BEPS Action Plan and its impact on global transfer pricing principles
BRICs attracting investment despite their tax systems
UN Manual – India chapter: A tale of the existing TP impasse
Why India has become the boy who cried wolf
Achieving the G8’s aims on beneficial ownership
Special features - September 2013
LVCR: Evasion, avoidance or abuse?
No escape: Businesses cannot ignore indirect tax
Enforcing foreign tax debts: How far back can you go?
How to manage an ATO audit
Albania: Tax appeal procedure in Albania
Brazil: Secretary of Finance defines spread for TP rules on interest payments
Bulgaria: Amendments to the Law on Gambling leads to diversion of investments for millions from Bulgaria
Cambodia: Independent contractor or employee
Canada: Canada clarifies tax treatment to non-resident partners on disposition of property held by a partnership
Chile: Notice to non-Chilean resident entities in the context of the indirect sales provision
China: Totality of Facts approach confirmed for granting of treaty benefits for dividends
Cyprus: Amendments made to VAT legislation
EU: Update on country-by-country tax reporting
France: New tax regime applicable to dividends and interests for French residents
Greece: New Greek Income Tax Code is supplemented by additional anti-avoidance rules
Hong Kong: Exchange of information
India: Ruling on Agency PE in case of marketing and distribution activities for group companies
Ireland: Ireland improves investment funds regime with limited partnership development
Italy: Italian government issues decree implementing exit tax
Laos: Lotteries and prizes now taxable
FYR Macedonia: VAT treatment of related entities
Mexico: New criteria to withhold VAT to foreign residents
Montenegro: VAT treatment in case of office premises purchase
Myanmar: Taxation of telecommunication services
New Zealand: New Zealand Inland Revenue releases statement on application of general anti-avoidance provision
Serbia: The new draft law on accounting
South Africa: Taxation Laws Amendment Bill of 2013 released for public comment
Spain: Does the sun attract unforeseen tax consequences? New obstacles to tax-neutral insurance portability within the EU
Switzerland: Switzerland’s proposed Corporate Tax Reform III – transfer pricing impacts
US Inbound: Medtronic: Motion for summary judgment
US Outbound: US Supreme Court holds UK windfall tax creditable
Vietnam: APA: An effective tool for transfer pricing management
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