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

Ernst & Young ITS Global Dispatch

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, August 2012

China further clarifies beneficial ownership for tax treaty purposes -- India releases draft guidelines for new anti-avoidance regulations (GAAR) -- Vietnam approves National Action Plan on transfer pricing for 2012-2015 -- Polish court challenges procurement support transactions with related entity -- Spain introduces new tax measures to reduce public deficit -- Argentina withdraws from tax treaty with Chile and Spain -- Brazil introduces reporting requirement for cross-border service and intangible transactions -- US releases FATCA Model Intergovernmental Agreement

ITS Global Dispatch, July 2012

Dutch Finance Ministry releases tax budget proposals for FY 2013 -- Danish Parliament adopts major new rules on company taxation -- Italy issues Circular Letter on settling international tax disputes, MAP process -- Spain, US announce agreement on new tax protocol -- Sweden present revised proposal tightening interest expense deduction on intra-group loans -- OECD publishes proposals for revised guidance on transfer pricing of intangibles -- Korea issues English language treaty claim forms -- Malaysia releases transfer pricing, APA rules -- Singapore clarifies rules on nontaxable gains on equity investment disposal -- US Treasury issues FATCA statements with Japan and Switzerland -- US Supreme Court rules on landmark health care law

ITS Global Dispatch, June 2012

India's Finance Bill 2012 enacted with major international tax amendments -- Denmark considers significant changes to company taxation -- Germany, Netherlands sign new tax treaty -- Spanish Supreme Court narrows entitlement to EU Parent-Subsidiary Directive -- Argentina releases proposed tax reform -- Brazilian court rules payments for services lacking know-how transfer not subject to withholding -- El Salvador issues transfer pricing guidelines

ITS Global Dispatch, May 2012

Canadian Budget 2012 includes international tax proposals -- New Argentine FX rules have tax consequences -- Brazil modifies transfer pricing rules -- Finland circulates draft interest expense restriction proposal -- Spain introduces changes to international tax framework -- Sweden proposes tightening interest limitation rules -- Delhi High Court rules on transfer pricing aspects of royalty payment to associated enterprise -- Japan's 2012 tax reform adopted -- Taiwan plans to resume capital gains tax on transfer or securities

ITS Global Dispatch, April 2012

UK releases anticipated Budget 2012, corporate rate reductions -- Indian Union Budget 2012-13 addresses Vodafone, other major changes -- Australia to amend General Anti-avoidance Rule -- Australia releases revised draft legislation on proposed Investment Management Regime -- Hong Kong announces new group-recharge deduction position -- Japan's NTA releases transfer pricing guidance for examiners -- European Commission announces new consultation on double "non-taxation" -- Italy amends exit taxation; opportunity for MNCs -- Italy issues draft regulations on notional interest deduction regime -- Argentina adopts new "Early Declaration System for Services" -- Colombian Constitutional Court rules minimum ownership for indirect tax credits for taxes on earnings from foreign shares unconstitutional

ITS Global Dispatch, March 2012

Tax Court of Canada issues landmark decision on "beneficial ownership" -- Argentina unilaterally terminates tax treaty with Switzerland -- Argentine tax authorities implement new "Early Import Declaration" mechanism -- Mexico reorganizes Certified Company Program; tax consequences for IMMEX companies -- Mexican tax refund opportunity for international airlines operating in Mexico --Belgium-Democratic Republic of Congo tax convention in force; Congo's first tax treaty -- Danish exposure draft includes important changes to company taxation -- Irish government publishes Finance Bill 2012 -- Indian tribunal rules on characterization of entities' activities for transfer pricing purposes -- Indonesian regulation affects MAP and APAs

ITS Global Dispatch, February 2012

Indian Supreme Court rules in long-awaited Vodafone case -- New Japan-Netherlands tax treaty effective -- Japan-Swiss tax protocol effective -- Korea revises tax laws -- Irish Budget reaffirms 12.5% corporate tax rate -- Israel raises tax rates, other changes -- Italy enacts austerity measures, positive tax changes -- Italy clarifies unlimited carryforward; applies to losses from 2006 -- New tax regime applies for Portugal's Madeira International Business Center -- Spain increases tax rates for 2012 and 2013 -- Brazil adopts adjustment mechanism on transfer prices of export transactions

ITS Global Dispatch, January 2012

New Switzerland-Netherlands tax treaty effective January 2012 -- Norwegian National Budget for 2012 contains major tax proposals -- Portuguese 2012 Budget Act proposals will impact cross-border transactions and foreign investment -- Angola proposes transfer pricing documentation rules -- New UK –South Africa tax protocol enters into force -- China announces new Shanghai VAT pilot to replace business tax -- Changes to Japan’s transfer pricing legislation effective -- Malaysia’s 2012 budget contains corporate tax incentives -- Colombia eliminates restrictions on foreign debt; intercompany loans now possible

ITS Global Dispatch, November 2011

Australian Treasury releases draft legislation for extending Petroleum Resource Rent Tax -- Australia releases shipping industry tax reform package; zero rate for Australian ship operators -- Hong Kong Inland Revenue considers R&D must be carried on directly by taxpayer for deduction -- Hungary submits 2012 tax bill to Parliament -- Draft Russia-Luxembourg protocol details available -- Canadian panel issues final R&D recommendations -- Mexico's IETU tax credit for maquiladoras extended

ITS Global Dispatch, October 2011

Dutch Finance Ministry releases FY 2012 budget proposals -- French National Assembly and Senate approve Second 2011 Amended Finance bill -- Israel excludes certain related party financing from transfer pricing rules -- China requiring foreign nationals to participate in social security system -- Indian transfer pricing cases address "associated enterprises" and cost contribution arrangements -- Taiwan defines amortizable "business rights" -- Brazil again amends Financial Transactions Tax (IOF) -- Colombia - Switzerland treaty to take effect

ITS Global Dispatch, September 2011

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

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Ernst & Young ITS Global Dispatch

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