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Doris Ho Alison Maxwell Makiko Takewaki Doris Ho, Alison Maxwell and Makiko Takewaki have become partners of DLA Piper's tax practice. Ho, in Hong Kong, advises multinational clients on the tax aspects of corporate acquisitions and restructurings.

Christian Chéruy has been appointed chairman of Loyens & Loeff's executive board. He advises clients on corporation tax and international tax and was previously head of the firm's tax practice in Brussels and was also country managing partner of the Brussels office.

Dajana Topic Pursuant to Article IV.4.d of the Constitution of Bosnia and Herzegovina (B&H), the Parliamentary Assembly of B&H on the 62nd session of the House of Representatives held on January 23 2014, and the 36th session of the House of Peoples held on March 12 2014, adopted the decision on approval for ratification of the agreement between B&H and the Republic of Macedonia for the avoidance of double taxation with respect to taxes on income and on capital. The agreement will apply to persons who are residents of one or both of the contracting states.

Donka Pechilkova The Bulgarian Ministry of Finance added an important new Appendix (Reference No.1 to Appendix 4) to the annual tax return that legal entities are obliged to submit for the calendar year of 2013. The appendix concerns transactions between related parties (both local and foreign ones) and transactions that were carried out with companies registered in offshore zones. In the application, all companies are obliged to disclose the amounts of such transactions that were settled during the year, as well as the type of the transactions (sales or purchases of goods, services and so on; loans; intercompany remunerations and other types of incomes or expenses). Due to the fact that the above-mentioned changes also concern transactions with physical persons, on March 10 2014 the National Revenue Agency published instructions for the filling out of Reference No.1 to Appendix 4 of the annual tax return declaration according to the text and meaning of Article 92 of the Corporate Income Tax Act and Reference No.7 to Appendix 4 of the annual tax return, related to Article 50 of the Income Taxes on Natural Persons Act. The aforementioned guidelines also attempt to clarify the ambiguity of the phrase "persons that have carried out transactions" included in Reference No. 1, which in some cases is replaced with "settled transactions", creating an obvious inconsistency in the method of reporting of loans and other transactions.

Tom Seymour The Australian Taxation Office (ATO) has released draft guidance on the new Australian transfer pricing rules. The draft guidance addresses the topics of documentation, penalties, and the 'reconstruction' rules. The new transfer pricing rules include specific provisions that, in certain circumstances, require the taxpayer to disregard in whole, or in part, the actual transactions entered into and replace them with hypothetical transactions. The intention was for the rules to be consistent with the 'exceptional circumstances' under which the OECD Transfer Pricing Guidelines permit the non-recognition of transactions.

Wensing Li

Ayesha Lau

Giuliano Foglia

Samantha Merle Having agreed on its content by the end of February, Luxembourg and the US signed an intergovernmental agreement (IGA) implementing the Foreign Account Tax Compliance Act (FATCA) on March 28. Luxembourg and the US negotiated a Model 1 IGA, requiring the Luxembourg tax authorities and the US Internal Revenue Service (IRS) to exchange information automatically on accounts held by US citizens and by persons resident in the US in financial institutions resident in Luxembourg. The IGA is reciprocal, which means the US will also have to report account information about Luxembourg individuals and entities in the US to the Luxembourg tax authorities. The IGA will enter into force either on the date of Luxembourg's written notification to the US that Luxembourg has completed its necessary internal procedures for the entry into force of the IGA, or on the date of the US written notification to Luxembourg that its applicable procedures for ratification of the amending protocol to the 1996 income tax treaty, signed on May 20 2009, have been satisfied, whichever date comes last.

Elena Kostovska A decision defining the categories of supply of goods and services for which the VAT responsible taxpayer is considered to be the entity to which the supply is being provided by another VAT-registered company was published in the Official Gazette 45/2014 and is applicable as of March 5 2014. The decision lists goods and services on which a reverse charge VAT mechanism is applied as of the aforementioned date and onwards. It also defines the appropriate steps that the involved parties need to follow in such transactions. Namely, the provider of the affected goods/services must indicate that "the VAT liability is transferred to the recipient of the goods/services according to Article 32, point 1 of the VAT Law" on the invoices issued. The provider will neither calculate VAT on the outgoing invoice, nor consider such outgoing VAT in their VAT return. The recipient of the goods/service, on the other hand, will now be obliged to calculate and pay the VAT to the Tax Office while also using their right for deduction of such input VAT.