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International Correspondents

The International Correspondents offer the latest developments and technical updates on the following jurisdictions. Please click on the relevant update based on the ITR Magazine, Indirect Tax, Corporate Tax, Tax Disputes Tax Technology and Transfer Pricing to access the articles.

If you would like to become an International Correspondent, please contact Margaret Varela-Christie.

ITR Magazine

Country Correspondent Latest update
Albania Eurofast Albania changes income tax law, introduces incentives for agro-tourism
Argentina PwC Regulations on certain tax reform aspects
Australia DLA Piper MLI, hybrid mismatch, MITs and staple structures, cross-border financing and reduced company tax rate
Bosnia and Herzegovina Eurofast Global BH's Republic of Srpska issues rulebook on tax adviser licence
Brazil Mattos Filho Brazil's Superior Court of Justice restricts taxpayer access to social security tax credits
Bulgaria Eurofast Global Bulgaria allows electronic storage of employment documents
Canada Blakes Beware of Canadian withholding tax and the breadth of the restrictive covenant rules
Chile PwC A new concept of deductible expenses
China KPMG Individual Income Tax (IIT) Law draft implementation guidance released
Croatia Eurofast Tax incentives for research and development in Croatia
Cyprus Eurofast Taxand New alternative investment funds legislation
Egypt Eurofast Central Bank of Egypt defends bank accounts secrecy
European Union PwC EU tax transparency is here to stay
Georgia Eurofast Georgia announces new Customs Code
Germany Nera Profit-split considerations in TNMM solutions in a post-BEPS world
Greece EY ECJ decision on bad debt VAT relief could serve as a guide in many Greek cases
Hong Kong KPMG Hong Kong's new R&D regime is here
India Dhruva Advisors Tribunal rules on agency permanent establishment and profit attribution
Indonesia Ali Budiardo, Nugroho, Reksodiputro Law Commencement of AEOI and priority target for tax audit
Iran Eurofast VAT exemption for hybrid and electric vehicles
Ireland Matheson Ormsby Prentice ATAD implementation continues with the introduction of CFC rules and exit charge
Israel Pearl Cohen Zedek Latzer Baratz
Italy Hager & Partners Transfer pricing adjustments: VAT treatment
Kosovo Eurofast Taxand & Vala Consulting Kosovo ratifies tax treaty with Austria
Luxembourg Deloitte EU Council agrees on quick fixe for intra-community transactions on goods and domestic VAT fraud
Macedonia Eurofast Global FYR Macedonia re-extends period for preferential VAT rate applications on first sale of residential buildings
Malta Camilleri Preziosi Extension to Malta's tax treaty network
Mexico Ritch Mueller Mexico introduces new tax incentives to stimulate financial sector
Montenegro Eurofast Global Citizenship by investment in Montenegro
Netherlands DLA Piper Dutch participation exemption and the write-down of receivables
New Zealand Russell McVeagh New Zealand considers tax on digital services
Norway Deloitte Alterations of the Norwegian tonnage tax regime
Poland MDDP Income tax on buildings: Amendments
Portugal's state budget brings several changes to VAT in 2019
Romania EY Tax audits “a disruptive routine for every taxpayer"
Russia KPMG Beneficial ownership concept in Russia: claiming treaty benefits becomes more complicated
Serbia Eurofast Global Serbia-San Marino DTA enters into force
South Africa Webber Wentzel South African dividend stripping rules: Impact on liquidations and cross-border share buybacks
South Korea Yulchon New rights for taxpayers subjected to a dawn raid
Spain Garrigues Spain - Taxand Should non-resident individuals pay taxes on their interest in non-resident companies owning real property in Spain?
Switzerland Deloitte New Swiss Principal Company and Swiss Finance Branch rulings to be phased out from January 1 2019
Turkey Centrum Consulting Recent tax developments
Ukraine Eurofast Global Ukraine tax code changes taking effect from January 1 2016
US Inbound Fenwick & West Altera decision reversal withdrawn
US Outbound KPMG New updates to CAP focus on transfer pricing issue resolution

Corporate tax

Country Correspondent Latest update
Ireland Mason Hayes Curran Ireland's budget 2019 introduces a new exit tax
Mexico Ritch Mueller Where are Mexico's special economic zones?
Portugal Vieira de Almeida Portugal: The new gateway to Angola

Indirect tax

Country Correspondent Latest update
Brazil Machado Brazil's proposal to define the export of services
Portugal Cuatrecasas Portugal VAT exemption on intra-EU supply of goods a “state of play"

Tax disputes

Country Correspondent Latest update
Brazil Mattos Filho The displeasures of the greatest tax dispute in Brazil

Tax technology

Country Correspondent Latest update
Mexico Creel Crowdfunding: the challenge of designing new tax regulation
Portugal PWC SAF-T in Portugal, a decade of tax data standardisation

Transfer pricing

Country Correspondent Latest update
Australia Deloitte Brand value, brand equity, and brand IP
Canada Deloitte
Germany Deloitte Lower tax court rules on direct shareholding requirement under EU PSD
Ireland Matheson ATAD implementation continues with the introduction of CFC rules and exit charge
Italy Valente Associati/GEB Partners
Japan Nagashima Ohno
Luxembourg PwC
Mexico BaseFirma
Mexico Deloitte Mexico court rules against taxpayer in transfer pricing case
Portugal Garrigues Liquidation proceeds sourced in Spain and exemption method for non-habitual tax residents
Sweden KPMG BEPS Actions 8 to 10: National interpretations of TP guidance
UK Deloitte
US Deloitte

International Correspondents