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Bulgaria: Treaty analysis: Bulgaria and UK sign new double taxation agreement

Petar Varbanov On March 26 2015, the Republic of Bulgaria and the United Kingdom of Great Britain and Northern Ireland signed a new Treaty for the Avoidance of Double Taxation (DTT) which will replace the DTT signed in 1987. The new treaty will introduce rules which differ considerably from the provisions now in force.

December 15 2015

Australia: Tax reform topics continue to dominate political scene in Australia

Chris Neil The debate regarding tax reform continues to dominate politics in Australia, with a number of alternative reforms being canvassed.

December 15 2015

Special features - December 2015 / January 2016

Read this month's special features for GCC - VAT and Intangibles

December 15 2015

Chile: Applicability of the beneficial owner concept for dividends in Chile

Germán Campos Kennett Fuenzalida Del Favero Double tax treaties (DTT) that follow the OECD's Model Tax Convention normally include the concept of 'beneficial owner' to determine the true owner of dividends, interests and royalties in order to apply special tax rates provided under such treaties.

December 15 2015

Canada: Canadian Federal Court pulls the reins in (slightly) on foreign information requests

Jean Marc Gagnon Alexandra Carbone In Amdocs Canadian Managed Services Inc. (ACMS), the Federal Court denied the Canada Revenue Agency's (CRA) request under section 231.7 of the Income Tax Act, Canada (Act) to compel ACMS to provide the CRA with documents and information requested in the course of a transfer pricing audit.

December 15 2015

Chile: Chilean IRS’s Anti-avoidance Bureau and the Administrative Consultation Procedure

Sandra Benedetto Jonatan Israel The entry into force of the Chilean general anti-avoidance rules (GAAR) envisaged by Law No 20.780 effective as of September 30 2015, has made the Chilean Internal Revenue Service (IRS) take specific actions regarding the organisation of its personnel, to address the challenges set forth by the Chilean GAAR regarding tax assessment.

December 15 2015

Germany: Exemption to Germany’s change-in-ownership rules expanded

Alexander Linn Thorsten Braun The German tax reform 2015, published in the federal gazette on November 5 2015, includes a new exemption from the strict change-in-ownership rules that result in the forfeiture of tax loss carryforwards.

December 15 2015

Italy: Companies migrating to Italy: New ‘internationalisation’ decree introduces rules to determine assets and liabilities’ tax basis

Giuliano Foglia Marco Emma The 'internationalisation' decree (formally, legislative decree No 147 of September 14 2015) has been recently published on the Official Gazette and is now effective.

December 15 2015

Indonesia: Indonesia issues a draft Bill for national tax amnesty; plans to cut taxes

Freddy Karyadi Chaterine Tanuwijaya Indonesia is set to shore up national coffers by providing a tax amnesty, while headline income tax rates will also be slashed.

December 15 2015

FYR Macedonia: Treaty analysis: FYR Macedonia ratifies double taxation agreement with Vietnam

Elena Kostovska On April 14 2015, the FYR Macedonian parliament ratified the tax treaty signed with Vietnam on October 15 2014. The ratification law was published in the Official Gazette No. 63 of April 20 2015.

December 15 2015

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