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  • Tax has changed dramatically since the first issue of International Tax Review came out in November 1989. Using a selection of articles – one from each year – Ralph Cunningham and Matthew Gilleard assess how many of those changes have been reflected in the publication over the past 25 years.
  • Christopher Roman Nick Thornton Christopher Roman and Nick Thornton have become new tax partners of Fried, Frank, Harris, Shriver & Jacobson. Roman specialises in the tax aspects of alternative investment funds, fund-related M&A and real estate, as well as representing investors in secondary sales of interests in private funds and investors in debt and equity transactions.
  • 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.
  • Read this month's special features on Singapore IP, GCC, Tax technology and Mexican energy reform
  • Donka Pechilkova The Bulgarian Parliament is discussing and amending several important tax laws including the VAT Law as well as the CITA and Tax and Social Security Proceeding Code; all of which will lead to important changes in the Bulgarian tax system. The most significant changes concern the VAT Law and are specifically related to amendments in the EU-specialised legislation, the Council Implementing Regulation (EU) No 1042/2013, amending Implementing Regulation (EU) No 282/2011 regarding the place of supply of services (the new European VAT package). Effective from January 1 2015, all entities that provide telecommunication, TV and radio services to end-consumers will be subject to VAT taxation in the jurisdiction where their end-user is located. As this could cause massive inconveniences for such companies, by introducing the obligation of VAT registration in every country they have end-users in, there is an option for applying a special VAT regime treatment for such cases. For that purpose, the providers should submit a special application for declaring of data via the information system MOSS (mini-one-stop-shop). The submission of the application, as well as the submission of the following quarterly mandatory reports will be done electronically, via the website of the National Revenue Agency for companies registered in Bulgaria. Companies registered in Bulgaria can submit their applications starting from October 1 2014 with the registration being effective as of January 1 2015.
  • Zoe Kokoni Cyprus, which has been long-established as a solid economic and business centre worldwide, seeks to reinforce its title as a beneficial investment hub by expanding its double tax treaty network and creating stronger economic and trade relations with other contracting states. On June 21 2013, Cyprus and Lithuania signed their first double tax treaty (DTT). Since then, the countries have ratified the agreement, which will enter into force on January 1 2015.