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  • The Tax Court of Cologne (Case ref. 2 K 2995/12) has referred the German anti-treaty shopping rule to the Court of Justice of the European Union (CJEU) to determine whether it complies with the fundamental freedoms of the EU and the Parent-Subsidiary Directive.
  • The details of the first agreement for the avoidance of double taxation (DTA) between Cyprus and Latvia became available in August 2016, providing information on the various applicable tax rates.
  • The US Treasury and Internal Revenue Service have finalised earnings stripping regulations that reduce the benefit of corporate inversions and limit the ability of companies to lower tax bills through transactions involving debt that does not support new US investment. The regulations also require large companies claiming interest deductions to document loans to and from affiliates.
  • The United Arab Emirates is on target to implement its VAT regime on January 1 2018, but with the final VAT Law yet to be published, businesses face a tight deadline to make sure they have the tools to comply with the new system.
  • The Hong Kong government gazetted the Inland Revenue (Amendment) (No. 2) Ordinance 2016 (the Ordinance) on June 3 2016, bringing into law a concessionary profits tax rate for qualifying corporate treasury centres (QCTCs). The new rules deem certain interest income and other gains as sourced and taxable in Hong Kong. Amendments to the earlier interest deduction provisions were also made to allow deductions for interest incurred on certain intra-group lending transactions.
  • The Curaçao tax budget was approved by parliament on July 23 2016 and published in PB 2016 No. 37. The changes will come into force by a separate state decree (Landsbesluit). At the time of writing, only the provisions to stimulate pension savings have come into force.
  • Transfer pricing (TP) rules have been present for more than a decade in the Albanian Corporate Income Tax (CIT) Law, but specific and detailed regulations on the application of these rules were only published in the Official Journal No. 70, dated May 20 2014. These changes have totally transformed Article 36 of the Law on Income Tax (No. 8438, dated December 28 1998) by adding seven more provisions on specific rules and actions.
  • Sponsored by Dhruva Advisors
    In India, intangibles that qualify for depreciation under the Income-tax Act, 1961 (Act) are defined to include "know-how, patents, copyrights, trademarks, licenses, franchises and any other business or commercial rights of similar nature". Since "goodwill" does not expressly find a mention in the list of intangible assets that qualify for depreciation, claims of depreciation on goodwill have been a matter of debate for a considerable time with decisions on both sides of the spectrum.
  • Sponsored by Russell McVeagh
    The New Zealand Inland Revenue has announced that it will be increasing the number of large taxpayers that it monitors as part of its Basic Compliance Package (BCP). Inland Revenue's announcement comes at a time of increased media and political attention on the tax affairs of foreign-owned multinational groups.
  • Sponsored by Deloitte Mexico
    By a majority vote, the Second Chamber of Mexico's Supreme Court of Justice ruled on the constitutional trials filed against the Income Tax Law that only allow employers to deduct certain payments.