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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.

Young Gee Park

Rajendra Nayak

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.

Donald Vella

David Cuellar

Peter Dachs The Tax Administration Act provides that a taxpayer is liable to pay tax once an assessment has been raised by the South African Revenue Service (SARS). In terms of section 164 of the Tax Administration Act, unless a senior SARS official otherwise directs in terms of subsection (3), the obligation to pay tax and the right of SARS to receive and recover tax will not be suspended by an objection or appeal or pending the decision of a court of law. In terms of section 164(2) a taxpayer may request a senior SARS official to suspend the payment of tax or a portion thereof due under an assessment if the taxpayer intends to dispute or disputes the liability to pay that tax.

Daniel Armesto

The Japanese Diet recently approved reforms to change the country’s general tax rules applicable to a foreign corporation (FC) with a permanent establishment (PE). The reforms, which highlight the OECD’s growing influence in Japan, are expected to create more controversy over taxable income and complicate foreign tax credit (FTC) positions.

The High Court of Gujarat in India, has upheld the use of price quotations as comparable uncontrolled prices (CUP) if the quotations are “reliable and authentic” in the case of Adani Wilmer, an edible oil producer.