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  • Ricardo Rendón of Chevez, Ruiz, Zamarripa y Cia. provides a commentary on the most important challenges multinational enterprises (MNEs) are facing in Mexico. Taxpayers performing transactions with foreign related parties, in particular, should take note.
  • Read this month's special features for GCC, Intangibles and Mexico
  • With the European VAT Directive set for a drastic rewrite, Joe Stanley-Smith gets the inside line from the man who oversaw this year’s implementation of the place of supply rules, and takes in advisers’ views on how stakeholders will be affected.
  • Alicja Sarna The Polish Parliament is finalising the amendments to the Polish Tax Ordinance (containing general provisions applicable to all taxes) that are long overdue. From January 1 2016, the 'in dubio pro tributario' rule (meaning 'in case of any doubts, rule in favour of a taxpayer') will come into force. According to this rule, in case of doubts related to the interpretation of the given legal provision, these shall be decided in favour of an entrepreneur applying the provision. From any taxpayer's (including foreign investors') standpoint, the newly amended rule is of great importance. It means that if, while properly following the rules of legal provisions interpretation, more than one outcome shall be found, the tax authorities cannot challenge the solution chosen by a taxpayer in line with any of the abovementioned outcomes of the interpretation. This rule will be complied with by the tax authorities (while auditing taxpayer settlements) as well as by the tax courts.
  • As governments around the world assess the best way to attract – and tax – R&D and intellectual property investment, Giulia Cipollini and Bianca Macrina of Withers in Milan look at the incentives taxpayers can avail in Italy, tracking the nuances of the Italian Patent Box regime from introduction to operation.
  • Charles Yorke and David Stainer, of Allen & Overy, review the latest UK Government proposals on improving compliance by large corporate taxpayers, including a ‘voluntary’ code of practice likely to give rise to fears of ‘mission creep’.
  • The latest international updates from our correspondents around the world.
  • Jock McCormack The Australian Government is continuing its strong focus on greater tax transparency, disclosures, reporting and stricter transfer pricing documentation requirements. The Australian Taxation Office (ATO) has also elevated its examination of perceived international tax abuses, including offshore marketing hubs, procurement hubs, permanent establishment (PE) status and financing arrangements. Multinationals entities (MNEs) are under the spotlight both internationally, through the OECD/G20 BEPS project, and domestically in Australia, by way of the Senate inquiry into corporate tax avoidance. Draft legislation has been publically released on August 6 2015, impacting MNEs with annual global revenues in excess of A$1 billion (US$740 million). This draft legislation will:
  • Ivana Blagojevic Pursuant to the Serbian Value Added Tax Act, taxable persons who are not established in Serbia are entitled to obtain a VAT refund if they have purchased movable goods and services if the following conditions are met: VAT was entered on an invoice drawn up in accordance with the VAT Act and the invoice was paid; The requested refund of VAT exceeds €200 in RSD equivalent, calculated according to the average exchange rate of the National Bank of Serbia valid on the day of the submission of the VAT refund request; The conditions, under which a taxable person established in Serbia has the right to deduct the VAT on supply on such movable goods and services, are met; A taxable person established outside of Serbia carries out in Serbia only transport of goods exempted from VAT (transport related to the import of goods, transport related to free trade zones, transport related to the export of goods) or international passenger bus transport subject to VAT on the section carried out in Serbia, and no other taxable activities; There is reciprocity between Serbia and the state of establishment of the foreign taxable person. Reciprocity exists between Serbia and the following countries:
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