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Germany: Treaty override declared constitutional

Alexander Linn Thorsten Braun In a decision dated December 15 2015 (and published on February 12 2016), Germany's constitutional court (BVerfG) confirmed that the legislature can enact tax treaty override provisions that aim to secure Germany's taxation rights, despite treaty provisions to the contrary.

March 30 2016

Canada’s 2016 Budget to be paid for by the US*

Negotiations for fictitious Budget funding from the US to Canada have hit a brick Wall in Mexico In an all-party parliamentary vote this month, the US Congress has passed a movement to send a cheque to the Canadian Prime Minister, Justin Trudeau, for his 2016 Budget.

March 30 2016

ANALYSIS: Osborne perpetuates UK core conflict on tax with Budget 2016

George Osborne, UK chancellor of the exchequer, has delivered his Budget 2016 speech, criticising “large companies that exploit loopholes” while lowering corporation tax to attract multinationals. The big ‘winners’ were small and medium-sized enterprises.

Matthew Gilleard, March 30 2016

How prepared are taxpayers and authorities in GCC countries for VAT?

Taxpayers in the GCC have been waiting for VAT for some time Oman's finance minister, Darwish bin Ismail Al-Balushi, appears to have confirmed that VAT in the Gulf Cooperation Council (GCC) region will be introduced in 2018, at a likely rate of 5%.

Joe Stanley-Smith, March 30 2016

Special features - April 2016

Read this month's special feature for Intangibles

March 30 2016

Australia: Capital gains tax withholding

Eddie Ahn On February 25 2016, the draft legislation introducing a new foreign resident capital gains tax (CGT) withholding regime received Royal Assent after being passed by the Australian Parliament. These rules take effect from July 1 2016 and impose a withholding tax obligation on purchasers of certain Australian real estate related assets.

March 30 2016

Bosnia and Herzegovina: Instruction on indirect tax exemption under Instrument for Pre-Accession Assistance Programme II

Igor Vujasinovic On November 11 2015, a new Instruction issued by the director of the Indirect Tax Authority of Bosnia and Herzegovina entered into force. The Instruction was published in the Official Gazette of Bosnia and Herzegovina on November 30 2015.

March 30 2016

US Inbound: US Tax Court upholds IRS authority to make aggregated TP adjustments

Jim Fuller David Forst Guidant v Commissioner, 146 TC No 5 (2016) is a transfer pricing case addressing the IRS's ability to make a single adjustment for a US affiliated group where different US members of the group engaged in intercompany transactions and different types of transactions occurred. In the case, six related US entities variously engaged in sales, licensing and services transactions with a large number of foreign manufacturing and distribution affiliates.

March 30 2016

Georgia: Georgia to amend corporate tax rules

Anna Pushkaryova The Ministry of Finance of Georgia has recently initiated important changes in the system of corporate income taxation, particularly related to the moment of taxation itself.

March 30 2016

The Brockman brief: The (post-BEPS) tax function of tomorrow

The evolution of international taxation, driven by the OECD’s BEPS Actions, is eliciting new ways of thinking about the effective management of an internal tax function.

March 30 2016

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