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  • The blueprint for how to tax cryptocurrencies like Bitcoin is still being developed Cryptocurrencies such as Bitcoin should be exempt from VAT, according to Advocate General Juliane Kokott's Opinion in a Swedish European Court of Justice (ECJ) case. The case, C-264/14, was referred to the ECJ by Sweden in June 2014 as the country looked for clarification on how to treat Bitcoin.
  • The Indian government has appointed Rodrigo Oreamuno as its arbitrator in the long-running Vodafone dispute.
  • Lyudmila Petkova, director of the Bulgarian Ministry of Finance’s Tax Policy Directorate, outlines the moves being made to counter tax fraud and tax evasion in Bulgaria at national level, as well as how this fits into wider regional and global efforts to tackle abuse.
  • 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.
  • Igor Vujasinovic On June 16 2015, in accordance with articles 7 and 8 of the Law on Indirect Taxation System in BIH (Official Gazette No. 44/03, 52/04, 34/07, 4/08, 49/09 and 32/13) in conjunction with article 25 of the Law on the Indirect Taxation Authority (Official Gazette 89/05) the Director of Indirect Taxation, with the approval of the Boards of Directors, issued a decision (the Decision) on the threshold for large VAT taxpayers. The Decision determines the period and prescribes the conditions which serve as a standard for determining which indirect taxpayers will have the status of 'large indirect taxpayers'.
  • Peter Dachs South Africa's new double tax agreement (DTA) with Mauritius was published in the Government Gazette of June 17 2015. In terms of article 28 of the new DTA, the provisions thereof shall only be effective in both countries from January 1 2016. The main changes introduced by the new DTA relate to dual residence for persons other than individuals, withholding taxes (dividends, interest and royalties) and capital gains.
  • 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:
  • Petar Varbanov On July 8 2015, the Bulgarian Parliament ratified the convention for the avoidance of double taxation concluded with the Kingdom of Norway. The convention will apply to persons who are residents of one or both of the contracting states and to any substantially similar taxes that are imposed after the date of signature of the convention in addition to, or in place of, the existing taxes. The existing taxes to which the convention will apply are taxes on income, municipal tax on income, tax relating to submarine petroleum income, pipeline transport of petroleum, national tax on remuneration to non-resident artistes, corporate income tax and patent tax. Income derived by a resident of a contracting state from immovable property (including income from agriculture or forestry) situated in the other contracting state may be taxed in that other state. Also, business profits of an enterprise of a contracting state will be taxable only in that state unless the enterprise carries on business in the other contracting state through a permanent establishment (PE) situated therein. Profits of an enterprise of a contracting state from the operation of ships, aircraft, and railway or road transport vehicles in international transport shall be taxable only in that state.
  • Hans Rudolf Habermacher