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Read this month's special features for GCC, Intangibles and Mexico

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’.

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.

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'.

Luis Manuel Viñuales So far 2015 has been an exciting year for Spanish tax practitioners thanks to the major reforms we have seen in the area of income taxes. Although the focus has been on a brand new Corporate Income Tax Law and on the relevant changes to the Personal Income Tax Law, we should not overlook the amendments made to the Non-Resident Income Tax Law (NRIT Law) and, in particular, to the tax treatment of capital gains obtained by non-residents on the transfer of shares of Spanish companies. The domestic NRIT Law in force until December 31 2014 stated that capital gains obtained by EU residents on the transfer of shares of Spanish entities could only be taxed in Spain if a) the underlying assets were mainly real estate located in Spain or if b) the seller owned at least 25% of the company during the 12 months before the transaction. Capital gains obtained by non-EU residents on the sale of Spanish non-listed entities were always taxed in Spain unless a tax treaty provided otherwise.

Hans Rudolf Habermacher

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.

Zoe Kokoni The Republic of Cyprus has once again kept its promise to international investors and introduced – on July 9 2015 – amendments to its tax legislation making the jurisdiction more attractive than ever before. The purpose of these amendments is to clearly establish Cyprus as the leading tax jurisdiction in the European Union, attract even further investment in Cyprus while at the same time harmonising its domestic laws with EU obligations. In a nutshell, the new tax legislation is as follows:

Mohamed Ezz 'Free zones' are one of the distinguished investment patterns where an investor can establish, set up and start his own project under the umbrella of this system. This system provides to the investor several benefits related to goods movement, either in or out, without dealing with different procedures in relation to customs, import, monetary system and other aspects of the procedures applied in similar transactions where the project is established under the aegis of the free zone system. In Egypt, the free zone system is regulated by Incentives and Securities of Investment Law No 8 of 1997, its executive regulation and modifications. This system is applied by the General Authority for Investment and Free Zones (GAFI). According to the regulations, while the free zone areas are located in Egypt, they are considered to be offshore areas.