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  • The accuracy of the Italian government’s revenue target for voluntary disclosures is being called into question Italy is extending a voluntary disclosure programme to companies (before the end of October) in a drive to recover €1.5 billion ($1.9 billion) of undisclosed assets. The programme could save taxpayers money and exempt them from criminal proceedings, but advisers are wary due to the aggression of the tax authorities during and after the country's 2009 tax amnesty.
  • Elena Kostovska The amended Profit Tax Law of FYR Macedonia, published in the Official Gazette No. 112 on July 27 2014, will enter into force on January 1 2015. The law will be applicable retroactively to 2014 as well, insofar as the determination of the profit tax base for the fiscal year 2014 is concerned. According to the new law and contrary to current practices (introduced as anti-crisis measures in 2008), the profit tax base will revert back to being equal to the actual profit (total revenue less expenses) plus any non-deductible expenses (the so-called "expenses unrecognised for tax purposes"). The change is expected to impact the profit tax base of all companies across all industry sectors. An additional novelty in the law – that goes against the trend of expanding the tax base – is the reduction of the profit tax base for the amount of business-related investments made in tangible and intangible assets (with the exception of cars, furniture, audiovisual equipment and art).
  • Jelena Zivkovic In March 2013 Montenegro and Azerbaijan signed a treaty for the avoidance of double taxation (a double tax treaty (DTT)) aimed at strengthening economic and trade relations between the two countries. The agreement came into force in January 2014. The agreement is applicable on taxes in both countries, including corporate income tax and personal income tax, as well as capital gains tax regardless of the type and method of collection.
  • Gambling with your tax dollars. And the amounts involved are not peanuts! Tom Coburn, Oklahoma senator, has released his annual Wastebook, in which he picks out wasteful or unnecessary government spending projects. Wastebook 2014: What Washington doesn't want you to read outlines 100 bizarre projects funded by taxpayer dollars during the past year.
  • Aleksandra Rafailovic The application of FATCA regulations by some Serbian Banks, and more specifically the required consent for collection and delivery of personal data and information about their bank account to the IRS as a prerequisite to open a bank account, have provoked strong reactions from Serbian citizens. The Foreign Account Tax Compliance Act (FATCA) is a set of regulations adopted in the United States to combat offshore tax evasion by US citizens and companies.
  • Peter Dachs In terms of the interest withholding tax (IWT) legislation which will become effective on January 1 2015 the term 'interest' is not defined. SARS has indicated that interest to which the IWT will apply is common law interest. However, 'interest' is defined in the Income Tax Act in section 24J. In addition, section 50B of the Income Tax Act (the IWT taxing provision) refers to section 9(2)(b) of the Income Tax Act. Section 9(2)(b) of the Income Tax Act applies exclusively to interest as defined in section 24J. On this basis, is 'interest' subject to the IWT 'interest' as defined in section 24J?
  • In the past three years, the eyes of the global public have been drawn to the normally quiet world of international taxation by corporations structuring their businesses in a way that is perceived to be for no other purpose than the avoidance of paying tax. In this light, Salman Bin Hassan Al-Thani, chief financial officer and director of tax at the Qatar Financial Centre Authority, analyses the transfer pricing regimes across the Gulf Cooperation Council (GCC).
  • Nancy Manzano and David Deputy, of Vertex, argue that today’s tax executives must have skills that include having confidence in using the technology required to manage their company’s tax affairs effectively.
  • Bob van der Made At the beginning of 2014, the European Commission announced a new focus on EU fiscal state aid. This was triggered by the unfolding OECD/G20s Base Erosion and Profit Shifting (BEPS) Action Plan and must also be seen in the context of the EU's own agenda to crack down on aggressive tax planning, tax avoidance and tax evasion by multinational companies. In concrete terms, this has resulted in the opening of a series of investigations into specific tax rulings and tax regimes. These cases have attracted a considerable amount of attention from the Commission. On specific tax rulings, the Commission took three decisions to launch formal investigations in this new context on June 11 2014, with regard to alleged aid to Apple in Ireland, alleged aid to FFT (allegedly Fiat Finance and Trade) in Luxembourg, and alleged aid to Starbucks in The Netherlands. On October 7 2014, the Commission announced a fourth in-depth investigation, namely with respect to alleged aid to Amazon in Luxembourg.