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Germany wants European patent box regimes withdrawn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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