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  • Elena Kostovska On July 14 2015, the government of FYR Macedonia approved the double tax treaty (DTT) between FYR Macedonia and the Kingdom of Saudi Arabia signed on December 15 2014. Pending approval from the Saudi Arabian authorities, the treaty will be effective from the calendar year following the one during which such approval takes place.
  • The agreement between the Government of Montenegro and the Government of the Republic of Austria for the avoidance of double taxation (DTA) was published in the Official Journal of Montenegro – International Agreements No 3 on March 26 2015 and entered into force on April 21 2015. The agreement was signed in Vienna on June 16 2014.
  • Mark Galea Salomone
  • The recent move by the UAE to slash fuel subsidies with effect from August 1 2015 is, once again, likely to ignite the debate on tax reform in the Gulf Cooperation Council (GCC).
  • Much time and attention has been devoted to planning for a post-BEPS world, from analysing systems that may need to be adopted to looking at how taxpayer-tax authority relationships are likely to change. But less has been said about the impact of BEPS deliverables on commercial contract documentation and the extent to which such contracts will be scrutinised. Jen Winterhalder, a solicitor in PwC Legal and Latika Sharma, a partner and head of PwC Legal’s intellectual property and commercial contracts team, focus on the importance of matching contract terms to commercial substance, both now and for the future.
  • Balance has been a big theme this month. And not just because it saw the 66th birthday anniversary of Philippe Petit, the French high-wire artist who gained fame in 1974 for his high-wire walk between the Twin Towers of New York's World Trade Centre, popularised in the 2008 British feature film 'Man on Wire'.
  • Country-by-country reporting (CbCR) has been heralded as the solution to the perceived problem that existing accounts for multinationals do not, and cannot, provide a true and fair view of business. This month’s Brockman brief takes taxpayers through the proposed model CbCR template.
  • 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’.
  • 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: