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Global Tax Alerts

Our global tax alerts, prepared by Deloitte professionals around the world, provide timely commentary and analysis on tax developments affecting cross-border transactions. For prior year alerts, please visit our alert archive.

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         Global Tax Alerts
Date Country Development
23 May 12 Brazil Court rules payments for outbound technical services not subject to withholding tax
23 May 12 Denmark Authorities rule EU parent is beneficial owner of deemed dividends
18 May 12 Denmark New rules facilitate entry of foreign investment funds into Danish market
11 May 12 European Union Investment funds prevail in French withholding tax case before ECJ
11 May 12 United States Treasury creates new exception from §956 for certain swap payments by CFC dealers
25 Apr 12 Denmark Corporate income tax bill presented to Parliament
23 Apr 12 United States Regs expand reporting of bank deposit interest paid to nonresident aliens beginning 2013
16 Apr 12 Finland EBITDA-based limitation on related party interest proposed
05 Apr 12 Spain More tax measures introduced to tackle public deficit
30 Mar 12 Canada Budget measures impact investment in foreign affiliates and tighten thin cap limit
28 Mar 12 United Kingdom Consultation launched on income tax rules on interest
21 Mar 12 United Kingdom 2012 budget measures affecting foreign multinationals
12 Mar 12 Australia Second exposure draft of Investment Manager Regime released
12 Mar 12 Brazil "Short-term" loan period extended for purposes of financial transactions tax
2 Mar 12 Brazil Government revises definition of "short-term" for purposes of IOF on foreign loans
2 Mar 12 Australia Changes proposed to strengthen general anti-avoidance rule
28 Feb 12 Canada Velcro Canada wins beneficial ownership case
15 Feb 12 France-Germany "Green Book" on tax convergence published; German ruling coalition announces plan for further business tax reform
14 Feb 12 United States IRS amends application of Section 367 to Section 304 transactions
14 Feb 12 United States Administration FY2013 Budget and Treasury descriptions of international tax proposals (Greenbook) released
13 Feb 12 United States Temporary and proposed dividend equivalent regulations issued under §871(m)
13 Feb 12 United States Foreign tax credit splitter and technical taxpayer rules issued
9 Feb 12 Italy Optional exit tax deferral introduced for deemed gains on intra-EU/EEA migration
8 Feb 12 Ireland Finance Bill 2012 generally positive for companies
6 Feb 12 Italy Tax authorities further clarify rules on utilization of tax loss carryforwards
3 Feb 12 Germany Tax authorities issue guidance on amended anti-treaty shopping rule
24 Jan 12 India Vodafone – Supreme Court holds sale of shares outside India between nonresidents is not taxable
18 Jan 12 Denmark Tax authorities lose another beneficial ownership case
4 Jan 12 Spain Tax measures introduced to tackle public deficit
2 Jan 12 Finland Change-in-control rules referred to ECJ on state aid grounds
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