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Bartosz Bogdanski July 1 2015 saw another amendment to the Polish VAT law. This time the amendments are not of crucial nature and were aimed at sealing the tax system and preventing fiscal frauds. Moreover, due to extinction of the temporal period agreed with the European Commission, the Polish government had to partially resign from the restrictions on the VAT deduction from fuel purchases to passenger cars. From the Polish government's perspective, the first part of the modifications seem to be the most important. It is well known that VAT frauds became a serious problem for the Polish state budget and a prevention of 'carousel fraud' is one of the priorities of fiscal policy. The most effective solution seems to be a broadening of the scope of the reverse charge mechanism for local supplies, which eliminates the mechanism of VAT input/output credits which is vulnerable to fraud. Starting from July 1 2015, supplies of portable computers (tablets, notebooks, laptops, mobile phones, including smartphones and video games consoles) shall be subject to the reverse charge mechanism if supplies are carried out to VAT registered taxpayers. The important issue is that the above mentioned goods will be subject to the reverse charge mechanism only if the total net amount of goods within the so called "economically uniform transaction" exceeded 20,000 PLN ($5,000).

Loreto Pelegrí

Ed Kroft, QC

Barcelona’s Neymar is known for his evasive dribbling on the pitch

Alexander Linn

Ayesha Lau

Samantha Schmitz-Merle The Luxembourg Government recently presented to parliament a draft law ratifying four double tax treaties (DTTs) concluded by Luxembourg with Andorra, Croatia, Estonia and Singapore and six protocols to existing DTTs concluded with the UAE, France, Ireland, Lithuania, Mauritius and Tunisia. While most of the protocols only aim to bring the exchange of information provisions of existing DTTs in line with OECD standards, the protocol to the Luxembourg-France DTT, the ratification process of which has been closely followed, amends the rules dealing with the taxation of capital gains on the sale of shares in property companies. The new DTTs generally follow the OECD Model Tax Convention. We present the main provisions. As far as residence is concerned, according to the DTTs concluded with Andorra, Croatia and Singapore, companies are, in case of conflict, considered resident in the country in which their place of effective management is located, in line with the current version of the OECD Model Tax Convention. However, under the DTT with Estonia, conflicts of company residence have to be settled by the contracting states by mutual agreement, meaning that the two countries will have to agree on the country in which the company will be considered as resident for DTT purposes. Even though solving conflicts of tax residence by the mutual agreement of the competent authorities is in accordance with the latest draft recommendations under the OECD's work to counter base erosion and profit shifting (BEPS), leaving it to the contracting states to solve these issues is an approach which runs the risk of being impractical and which means a lot of legal uncertainty for taxpayers.

Andrea Pavlicevic Since becoming independent in 2006, the government of Montenegro has recognised the need to eliminate obstacles and reform the business environment to open the economy to foreign investors and bring it closer to the European Union. One important recent step in this regard is related to the seventh art. The government plans to adopt the Law on Cinematography, which provides the return of part of the funds spent by foreign producers filming in Montenegro.

With the US Foreign Account Tax Compliance Act (FATCA) reporting deadlines approaching, foreign financial institutions (FFIs) should ensure they understand the impact of FATCA in their organisation and the compliance requirements they are subject to under the intergovernmental agreement (IGA), signed or agreed in substance, between the US and several countries in the GCC including: the Kingdom of Saudi Arabia (KSA), United Arab Emirates, Kuwait, Qatar, and Bahrain.

Bob van der Made On June 17 2015, the European Commission (EC) presented an action plan setting out a new approach to business taxation, to meet the goal of fairer and more efficient taxation and to effectively tackle corporate tax avoidance. The stated objectives are: Re-establishing the link between taxation and where economic activity takes place; Ensuring that member states can correctly value corporate activity in their jurisdiction; Creating a competitive and growth-friendly corporate tax environment for the EU; and Protecting the Single Market and securing a strong EU approach to corporate tax issues, including on implementing OECD BEPS actions, dealing with non-cooperative tax jurisdictions and increasing tax transparency. A new legislative proposal for mandatory (at least for MNEs) common consolidated corporate tax base (CCCTB) will be presented in 2016. Implementation in two stages: first a common tax base (CCTB), with consolidation to follow at a later stage. If unanimity is not achieved, it is possible that a CCTB could proceed for selected member states under enhanced cooperation.