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By Cheng Chi, Ho Yin Leung and Eden Yamaguchi of KPMG China.

Ernie Lai King has joined Hogan Lovells in their Johannesburg office. King was previously head of the China Group at Edward Nathan Sonnenbergs and will now lead Hogan Lovells’ tax and China practices in South Africa.

One of the most contentious issues being considered as part of the OECD’s base erosion and profit shifting (BEPS) project is the notion of country-by-country reporting (CbCR) of multinational companies' tax information. Frank Schoeneborn, head of group operational transfer pricing in the finance and accounting division at Merck Group in Germany, steps forward in time to take a hypothetical look at the reporting standard five years after implementation.

Kilpatrick Townsend & Stockton has added Heather Preston as a corporate tax partner in its Atlanta office.

Rossitza Koleva The Bulgarian National Revenue Agency and the US Department of Finance agreed on the text of the agreement between Bulgaria and the US, aimed at improving the compliance of the tax legislation from an international aspect and the enforcement of the Foreign Account Tax Compliance Act (FATCA), voted in 2010. To this effect, Bulgaria is included in the list of countries the US is having a FATCA agreement in force with. FATCA obliges all foreign financial institutions (FFIs) to provide information to the International Revenue Service (IRS) related to those financial accounts which belong to US taxpayers or foreign companies that are controlled by US taxpayers (with more than 10% direct or indirect participation). FFIs that do not participate in FATCA will be subject to 30% withholding tax in the US, which will make their operations on the US markets extremely difficult. Thus, US taxpayers who own financial assets abroad must declare them in the IRS and for this purpose FATCA introduces a regime according to which the FFIs can choose either to assist IRS (participating) or not (non-participating).

Anastasia Sagianni

Elena Kostovska The corporate income tax system in FYR Macedonia – since its groundbreaking revamping in 2011 – has been mostly concerned with the unrecognised (non-deductible) expenses of a company for the purposes of determining its tax base, as opposed to the actual profit of a company. However, within the past three years of the validity of this novel corporate income tax regime, and due to the resulting shrinking of the tax base of companies, the government and tax authorities are finding themselves in a constant loop of amendments aimed at widening the tax base by effectively introducing new categories in the so-called unrecognised expenses list.

Chris Harker New Zealand's Inland Revenue has recently finalised a series of public rulings (BR Pub 14/01 to 14/05) regarding the ability of a New Zealand resident partner of an Australian limited partnership (ALP) to claim foreign tax credits for tax paid by the limited partnership. The rulings apply from the 2013/2014 income year. The rulings concern ALPs that are treated as companies for Australian tax purposes, but are fiscally transparent for New Zealand tax purposes. The rulings will, however, be of general interest to persons that are considering New Zealand inbound or outbound investment involving a hybrid entity (that is, an entity that has transparent tax treatment in one jurisdiction, but that is taxed as an entity in its own right in another).

Privacy concerns still hamper the re-proposed rule What a messy few months Argentinean football star, Lionel Messi, has had with the Spanish tax authorities. We are used to seeing the diminutive star running rings around his opponents on the football field, but recently the question has arisen as to whether Messi has been trying to run rings around the taxman, too. Thankfully for him, and the rest of his countrymen, his performance on the pitch has not suffered, and now neither will his bank balance, after the case against him in relation to charges of tax fraud was dropped by prosecutors. Leo can now let out a sigh of relief and focus all of his attention on the 2014 FIFA World Cup in Brazil safe in the knowledge that he will not have to swap his blue and white jersey for an orange jumpsuit.

Vicente Bootello