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The Tax Court of Cologne (Case ref. 2 K 2995/12) has referred the German anti-treaty shopping rule to the Court of Justice of the European Union (CJEU) to determine whether it complies with the fundamental freedoms of the EU and the Parent-Subsidiary Directive.

The 2016 Canadian federal budget proposed to significantly broaden certain rules aimed at preventing the use of back-to-back (BTB) loans to circumvent Canadian tax rules governing the withholding tax treatment of interest payments made in relation to certain transactions involving intermediaries and non-arm's length non-residents.

The details of the first agreement for the avoidance of double taxation (DTA) between Cyprus and Latvia became available in August 2016, providing information on the various applicable tax rates.

The US Treasury and the IRS have released final regulations under Internal Revenue Code, section 385. They are an improvement over the regulations proposed in April 2016, but still contain many developments that should be noted by inbound organisations.

The Supreme Court recently held that a UK holding company was the beneficial owner of dividends it received from a Korean taxpayer for purposes of the Korea-UK income tax treaty (the treaty). The court reached its decision despite the existence of certain facts that put the taxpayer at a disadvantage when looking at earlier beneficial ownership decisions that applied the substance-over-form doctrine in a treaty context.

The enactment of the Romanian Fiscal Code in January 2016 brought significant changes to an individual's tax residency position. For the first ever time, the Romanian legal framework provides for a 'split year' residency.

Taxpayers may be able to recover several years of paid energy taxes under a long-awaited opinion from the Supreme Court on whether certain taxes are constitutional.

The UK's new legislation to tackle hybrid mismatches, which enters into force on January 1 2017, may impact certain Swiss principal structures that are benefitting from a so-called Circular No. 8 regime.

The agreement for the avoidance of double taxation (DTA) between Serbia and Kazakhstan was signed on August 28 2015 in Astana, and has since been approved through diplomatic channels by both parties.

The US Treasury and Internal Revenue Service have finalised earnings stripping regulations that reduce the benefit of corporate inversions and limit the ability of companies to lower tax bills through transactions involving debt that does not support new US investment. The regulations also require large companies claiming interest deductions to document loans to and from affiliates.