March 2016

Main

LONG READ: Latin America’s 2015-2016 tax treaty network

Time for (trans)action

The Brockman brief: CbCR: Surrogate parent entity – good idea, but will it work?

The Cunningham column: China drags its tax system into line

Deals of the month

EC moving away from OECD model on arm’s-length principle

Google defends UK tax practices in boisterous PAC hearing

Global agreement expands international tax cooperation

India GST – Still alive despite lack of Budget prominence

The tax transactional survey 2016

PoEM – Changing the Indian tax landscape

Special features - March 2016

Can BEPS provide a cure to the Kimberley Process blues?

State and local cooperation key to success of Chinese reform

Albania: Albania and Morocco sign tax treaty

Brazil: Brazilian Federal Revenue Agency publishes tax decision on contribution of know-how into capital

Brazil: Brazil introduces regularisation programme for certain assets held abroad

Canada: Canadian voluntary disclosure programme rises in popularity

Chile: Chile’s new (not-so-)thin capitalisation rules

China: China’s 150% super deduction regulation

Cyprus: Reduced withholding tax rate on dividends from Russia to Cyprus

Georgia: Cyprus – Georgia tax treaty enters into force

Germany: German Federal Tax Court questions constitutionality of interest deduction limitation rule

Indonesia: Indonesia updates Asian treaty network; issues foreign customers’ exchange of information for financial institutions

Italy: Italy enhances IP regime and introduces grandfathering period for trademarks

Luxembourg: Luxembourg and the new face of the Russian tax realm

FYR Macedonia: FYR Macedonia and Israel sign tax treaty

Malta: Malta publishes Common Reporting Standard guidelines

Montenegro: Montenegro’s tax treatment of foreign corporate executives

New Zealand: New Zealand continues tax administration reform

Norway: Foreign rig owner wins Norway Supreme Court case concerning limited tax liability

Poland: Poland introduces new R&D tax incentives

Serbia: Serbia signs 66th double tax treaty

Spain: Control of state aid in Canary Islands investments

Switzerland: Swiss securities transfer tax – No new treatment for Swiss fund managers

Turkey: Constitutionality of the Turkish withholding tax rules: new decision, old school approaches and still a lack of legality

US Inbound: US revises treaty model

US Outbound: US issues proposed CbCR regulations

Relief from the bizarre taxes

Hopping mad Methodists boycott Cadbury for Easter

International updates - March 2016

International updates - April 2016

International Correspondents

Features

New Analysis

Tax Relief

Special Features

Editorial

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Norway: Foreign rig owner wins Norway Supreme Court case concerning limited tax liability

The Supreme Court in Odfjell Rig (case Rt-2015-1360) concluded that the limited activities carried out onshore were not sufficient to create the taxable nexus to Norway that would be necessary for tax to apply to the income deriving from a bareboat charter.

Daniel M H Herde, March 09, 2016