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Sean Foley

Mario Ortega Calle

Gabriel Sincu The Romanian economy has a great need for new investments to fulfil its huge growth potential. Whether direct or indirect, foreign or domestic, private or public, investments are key elements in the race to recover the economic gap existing between Romania and the western European countries. With this in mind, the Romanian authorities introduced in 2014 two sets of rules with the clear goal of increasing investment levels and making the country more attractive for new and existing players in the economy.

Henrik Brødholt On October 8 2014 the Norwegian government presented the national Budget for 2015. As expected there were no substantial changes regarding corporate income tax, as the government awaits the finalisation of the tax consideration by the Scheel working party. There were, however, changes to partnership taxation and exit taxation, as well as revisions to the R&D credit. The national Budget has proposed that partners in Norwegian silent partnerships (IS) and limited partners in limited partnerships (KS) shall be disallowed the ability to use tax losses arising from these partnerships as a means of offsetting taxable profit from other sources. The Budget instead allows for tax losses to be carried forward and offset against future profits, and/or a taxable gain from selling shares, in the same IS or KS. The proposed changes are justified by way of increasing equal treatment of different company types, reducing potential abuse and for general tax rules simplification. The proposed amendments may result in significant changes in the structure, timing and total tax costs for IS and KS companies. These rules are proposed to take effect from 2015.

Aleksandra Rafailovic On September 1 2014, the Law on Public Notary came into effect in Serbia. This law was already passed in 2011, but it was postponed twice because of low levels of interest from candidates in taking the exam for this title. As part of the legal and judicial reform programme in Serbia, some of the main reasons for introducing notaries were the need for administrative relief of courts, increase efficiency and greater legal certainty for citizens.

Multinational corporation

Former competition commissioner, EU

Chilean finance minister

Samantha Schmitz-Merle

Tim Stewart The Inland Revenue has issued a final statement (Income tax: scenarios on tax avoidance) which considers whether New Zealand's general anti-avoidance rule (GAAR) would apply to three instances. The final statement follows the release in May 2014 of a draft statement. The GAAR and the draft statement were considered in an article in the September issue of International Tax Review (see "NZ Inland Revenue releases draft GAAR guidance", August 29 2014). As explained in that article, when determining whether an arrangement is a tax avoidance arrangement and therefore subject to the GAAR, Inland Revenue applies a parliamentary contemplation test. Under this test, the question is: "Does the arrangement, viewed in a commercially and economically realistic way, use (or circumvent) the relevant [specific] provisions in a manner that is consistent with parliament's purpose?" If not, the arrangement will be a tax avoidance arrangement unless the tax avoidance is "merely incidental" to some other purpose or effect.