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Christiana Nicolaou If you already own an intellectual property (IP) box company in Cyprus, or if you are considering such a move, recent international developments at G20, OECD and EU level, along with the Cyprus Ministry of Finance's [MoF] December 30 2015 announcement, require your special attention.

John Leopardi Alexandra Carbone In March, the Federal Court of Appeal (FCA) overturned the Tax Court of Canada (TCC) judgment in The TDL Group Co. (TDL). The FCA allowed the interest deduction claimed by TDL on funds borrowed from its direct US parent, Delcan, that were used to purchase additional common shares of its wholly-owned subsidiary, Tim Donut US Limited (Tim US). A summary of the TCC decision was published on March 30 2015.

Khoonming Ho Lewis Lu On March 24 2016, China's Ministry of Finance and the State Administration of Taxation jointly issued Circular Cai Shui [2016] 36 (Circular 36) which contains the Value Added Tax (VAT) rates and rules applicable to the expansion of China's VAT system to several key sectors such as real estate and construction, financial services, and lifestyle services, which take effect from May 1 2016.

Bob van der Made The European Commission (EC) has proposed legislation requiring public country-by-country reporting (CbCR) from many EU enterprises.

Dorina Ndreka Property taxes in Albania are regulated by the law on the local tax system and consist of the building tax and the agricultural land tax. Subject to the property tax are all physical and legal persons, locals or foreigners, who own an immovable property (either agricultural land or a building). Taxpayers are determined based on legal documents that prove the ownership of the property.

Alvaro Pereira Ruben Gottberg In November 2011, the Brazilian Government signed the Convention on Mutual Administrative Assistance in Tax Matters (CMAAT), which establishes rules for sharing tax information between the G20 countries. In general terms, the CMAAT provides for all possible forms of administrative cooperation between the parties in the assessment and collection of taxes, in particular with a view to combating tax avoidance and evasion, while considering high standards of confidentiality and protection of personal data. The CMAAT was approved by Brazil's Senate on April 14 2016. It should enter into force three months after the deposit of the ratification instrument.

Alexander Linn Thorsten Braun On February 4 2016, the European General Court (EGC) issued a decision upholding the 2011 decision of the European Commission that the 'restructuring exception' in Germany's rules relating to the carryforward of tax losses by companies in financial difficulties constituted illegal state aid under EU law.

David Jakovljevic Croatia and Luxembourg signed a treaty on the avoidance of double taxation (double tax agreement, DTA) on June 20 2014, which recently entered into force on January 13 2016.

Jim Fuller David Forst The IRS released far-reaching proposed regulations on determining whether an interest in a corporation is debt or equity. The earnings stripping rules (Code section 163(j)), with which inbound taxpayers are certainly familiar, are not affected by the proposed regulations. Rather the proposed regulations provide a separate set of rules which taxpayers must consider.

Nicola Saccardo Marco Valdonio On March 30 2016 the Italian Revenue Agency issued comprehensive guidelines on the tax treatment of leveraged buyout transactions (LBOs) and similar acquisition structures, with a particular reference to investments by private equity funds.