OECD proposes clarifications to term "beneficial owner" in Model Treaty -- Norwegian court puts commissionaire structures at risk -- Australian government issues 2011-12 federal budget -- China focusing on financial services transfer pricing -- Hong Kong court issues favorable offshore profit decision -- Japan releases circular on corporate tax treatment of damages from March disaster; procedures to finalize 2011 tax reform on hold -- Brazilian government issues thin capitalization guidance -- Tax Court of Canada renders important transfer pricing decision

ITS Global Dispatch,May 2011

The Ernst & Young ITS Global Dispatch brings you the latest developments in international tax news.

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European Commission Action Plan to strengthen fight against tax fraud and tax evasion -- Protocol to Belgium-UK treaty entered into force -- French Parliament approves Finance Bill 2013 -- Ireland's 2013 Budget published --Latvia introduces new participation exemption, withholding tax regime -- Spanish Parliament enacts law affecting Spanish resident entities and PEs --UK releases guidance on administering US-UK FATCA agreement -- Argentina to begin new "Early Declaration for Payments Abroad" -- Mexican Congress approves tax amnesty --US-Spain sign comprehensive tax protocol

ITS Global Dispatch, December 2012 - January 2013

Germany's Annual Tax Act to implement Authorized OECD Approach for PEs --  New Finnish Bill would restrict interest deductibility --  Luxembourg Government presents amended 2013 Budget proposals -- Tightened Swedish interest limitation rules and lowered CIT rate approved by Parliament -- New start date for Australia's proposed amendments to GAAR -  Hong Kong signs tax treaty with Canada -- Argentina ratifies Multilateral Convention on Mutual Administrative Assistance in Tax Matters -- US  issues second Model FATCA Intergovernmental Agreement -- US FATCA negotiations moving forward

ITS Global Dispatch, November 2012

UN releases draft Transfer Pricing Practical Manual for Developing Countries -- OECD issues revised draft changes to Commentary on Article 5 (PE) and beneficial ownership -- Australia announces tax changes in Mid-Year Economic and Fiscal Outlook -- Colombian tax bill introduces new consumption tax, income tax supplement, anti-abuse rules and  transfer pricing changes -- Malaysia issues 2013 budget proposals -- Portugal's State Budget Law for 2013 submitted to parliament; includes new interest deduction limitation rules

ITS Global Dispatch, October 2012

India publishes rules for implementing Advance Pricing Agreements -- India's Advance Ruling Authority upholds nontaxable treatment of share buyback by Mauritius company -- Japan's NTA publishes voluntary transfer pricing information checklist -- Taiwan clarifies character of payment to foreign entity for online database services to Taiwanese customers -- Brazil converts Provisional Measure into Federal Law amending transfer pricing rules -- Panama introduces changes to transfer pricing regulations -- US, UK sign bilateral FATCA agreement -- Russian issues guidance on transfer pricing documentation -- Sweden proposes reduction in corporate tax rate

ITS Global Dispatch, September 2012

Canada releases legislative proposals to implement 2012 federal budget --  Australia enacts major transfer pricing law changes -- China to expand VAT pilot program to 8 more locations, including Beijing -- India issues tax policy announcements to address business concerns -- Japanese Diet passes consumption tax reform bill -- Taiwan to reinstate capital gains tax on Taiwan securities trading -- Denmark considers bill whereby all loans from companies to shareholders considered non-repayable withdrawals, i.e., dividends, contributions or salary income -- France's Second Amended Finance Bill for 2012 final -- Italian Supreme Court rules on PE  issue related to Italian company acting as commissionaire for Dutch principal -- Israel considers temporary benefit on repatriation of funds

ITS Global Dispatch,May 2011

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