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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.

Hans Rudolf Habermache

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.

Jelena Zivkovic The Montenegrin government announced a public tender for the sale of 50.75% of share capital of the state-owned arms company Poliex from Berane. The tender was announced in line with the privatisation programme adopted by the Privatisation Council of the Montenegro Government. Poliex is a joint stock company with capital of €2.2 million ($2.7 million) and 389,751 ordinary shares with a nominal value of €5.68 per share.

The Treasury has provided welcome guidance for jurisdictions in FATCA limbo The US Treasury has responded to calls for clarity about the status of jurisdictions that have agreed in substance an intergovernmental agreement (IGA) with the US to implement the Foreign Account Tax Compliance Act (FATCA), but will not have signed it by the end of 2014.

Director-general – DG Taxation and Customs Union, European Commission

Elena Kostovska The Law on Value Added Tax in FYR Macedonia underwent several revisions in 2014, with the most recent reform taking place in early September. Published in the Official Gazette no. 130/2014 and effective as of September 11 2014, the new Law on VAT introduces some amendments that are expected to impact a large percentage of small and medium businesses. According to the Law, as of 2015, the threshold for mandatory VAT registration is being slashed in half, from the current MKD 2 million ($40,000) in annual turnover to a mere MKD 1 million. It is expected that this change alone will make VAT registration mandatory for a large number of micro and small entities that are currently outside the VAT scheme based on lower annual turnovers. As a reminder, companies that have elected not to voluntarily register for VAT purposes before realising the turnover threshold are required to do so within 15 calendar days of the day on which the threshold turnover is reached. As the Law will be in force as of 2015, this will create an obligation for a large number of companies that will reach a turnover of MKD 1 million within the 2014 fiscal year to mandatorily register for VAT purposes in the first 15 days of 2015.

Ayesha Lau