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Rajendra Nayak

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Rene Zulauf

Alexander Linn

Rhonda Gregory Inland Revenue and the Treasury have released an issues paper proposing to reform the way non-resident withholding tax (NRWT) applies to interest. Generally, under existing law, where New Zealand-sourced interest is paid to a non-resident lender that does not have a New Zealand branch, the borrower must withhold NRWT at the rate of 15% (although this is usually reduced to 10% under any applicable double tax agreement). In the case of interest paid to a lender that is not associated with the borrower, the rate of NRWT can be reduced to 0% by the borrower paying an approved issuer levy (AIL) of 2%.

Ivana Blagojevic The Serbian Government passed the decree on conditions and procedures for the attraction of direct investments, which was published in the Official Gazette of Serbia No. 28/2015 from March 20 2015. The decree entered into force on March 21 2015. The decree provides for subsidies for investments into the Serbian market and regulates who can apply for the subsidies, the volume of subsidies and the procedure of applying and granting subsidies.

Nemanja Paskulov The news release from the Canadian Ministry of International Trade highlighted the importance of FIPAs for ensuring the fair treatment of investors and the creation of a more predictable and transparent business environment through reciprocal, legally binding provisions, by setting out clear rules governing investment relations, including in areas of dispute resolution and protection against discriminatory and arbitrary practices, giving businesses greater confidence to invest. Furthermore, the Ministry announced that Serbia is an important commercial partner in southeastern Europe, identifying many areas of potential growth for Canadian investment in Serbia, from the extractive and resource industries and the energy and power generation, to transportation infrastructure and agri-food sectors. Canada-Serbia relations have been strengthened in recent years by a number of bilateral agreements, including a double taxation agreement and social security and air transport agreements.

"From a political perspective, aggressive tax planning and the overall lack of transparency across Europe have a corrosive effect on the principle of 'no taxation without consent'. Democratic accountability is also at risk when large corporations are in a position to make member states compete to house their headquarters or operations: the prerogative to set the level of taxation is no longer exercised by citizens and their representatives, but by multinational corporations."

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Peter Dachs It has been widely reported that the South African Revenue Service (SARS) is making application for the sequestration of Julius Malema, the head of the Economic Freedom Front political party, after the 'collapse' of a settlement agreement between the parties. These reports state that Malema did not correctly disclose the source of the funds used to settle the tax debt which formed part of the agreement. In determining whether settlement is appropriate the Commissioner of SARS must consider a variety of factors including the potential costs of litigation to SARS and its likelihood of success, factual or evidentiary difficulties which would make litigation or alternative dispute resolution problematic, whether settlement is in the best interest of good management of the tax system, overall fairness and use of SARS' resources.