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Igor Vujasinovic On October 22 2015, the National Assembly of the Republic of Srpska adopted amendments to the Law on Property Tax. The Law entered into force on January 1 2016.

Rolf Saastad Wensing Li In a ruling from November 12 2015 (Herkules), the Norwegian Supreme Court stated that carried interest for tax purposes is to be treated as operational income in the general partner, rather than income of employment, which was the tax authorities' view. Hence, the tax authorities' view that the carried interest should be treated as personal income taxed at approximately 50% was overruled by the court. The court emphasised that the basis for an assessment of income classification and income allocation for tax purposes is primarily the agreements entered into by the taxpayers, to the extent they reflect the realities and are mutually binding.

Fred Lo, vice president and global head of tax at Yanfeng Global Automotive Interiors, a joint venture between the automotive interiors businesses of Johnson Controls and Shanghai Motors, analyses recent tax treaty trends, focusing on mismatches in treaty terms and why some countries are more equal than others.

Álvaro Pereira Ruben Gottberg According to the recently enacted Law 13.202/15, the social contribution on net income (CSLL, by its Portuguese acronym) falls under the scope of Brazilian double tax treaties (DTTs).

Nancy Diep Canada's thin-capitalisation rules operate to deny all or part of an interest expense in Canada for a taxation year if the amount of the interest-bearing debt owing by a borrower to specified non-residents (that is, persons who hold – or do not deal at arm's-length with persons that hold – 25% or more of the applicable votes or value of the borrower) exceeds the borrower's equity by more than a 1.5:1 ratio. Any excess interest that is not deductible for a taxation year is also treated as a deemed dividend subject to Canadian withholding tax.

Alexander Linn Thorsten Braun Germany's Federal Tax Court (BFH) has asked the German Ministry of Finance to join a pending case on the intra-group exception to the German real estate transfer tax (RETT) (case ref. II R 62/14). One of the issues raised by the BFH relates to the question of whether or not the intra-group exception has been notified to the European Commission as potential state aid.

Khoonming Ho Lewis Lu On October 30 2015 China's Ministry of Finance (MoF) and State Administration of Taxation jointly issued Circular Caishui [2015] 118 (Circular 118) which introduces value added tax (VAT) zero-rating for certain exported services, to replace the existing VAT exemption treatment. VAT zero-rating means that a taxpayer not only does not pay VAT on the services it performs, but is also entitled to full input VAT credits (and if applicable, refunds) for the expenses it incurs which relate to providing those services.

Andrey Grachev Anton Borisichev The Russian State Duma has accepted a legislative proposal (Draft Law No 962487-6) related to new VAT rules for electronic services (e-services). In all likelihood the draft law will be amended several times before its final adoption and enforcement, but content analysis shows its main purpose is to get foreign companies registered for VAT in Russia and remitting tax on services that are electronically supplied.

Many of our readers will have been eagerly awaiting the sound of ITR's February issue hitting their hallway floor after we moved our landmark Global Tax 50 feature to this edition to accommodate last month's BEPS Special.

David Forst, Jim Fuller, Adam Halpern and Andrew Kim of Fenwick & West provide an update on recent US Treasury and IRS action which is impacting outbound transfers to foreign corporations. The impact of the Altera case, as well as recent anti-inversion action, is also analysed.