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Rajendra Nayak

Jelena Zivkovic Budva Municipality, the pearl of Montenegrin tourism, is addopting new incentives for domestic as well as foreign investors for the construction of new hotels and for owners of private accomodations. A year ago, the Budva municipality government adopted an incentive acoording to which investors that are investing in construction of four and five stars hotels are liable to pay €30 ($41) per square metre for local communal fees that is already 10 times less than the fees in previous periods. Now, the municipality intends to reduce the fees to zero.

Inspired by the Fair Trade Mark, the Fair Tax Mark is a new standard to promote companies pursuing ethical tax policies and reward good behaviour among taxpayers. Richard Murphy, founder and technical director of the campaign, explains why it is necessary.

Donald Vella

Anastasia Sagianni The Serbian transfer pricing legislation follows the OECD guidelines and requires that transactions between related parties should be carried out in an arm's length basis. The Serbian tax authorities through the TP Rulebook that was published on July 12 2013 in Official Gazette of RS no. 61/2013, determine the general principles of TP in Serbia. Taxpayers should have the appropriate TP documentation in place to defend their policies in a potential tax investigation. Companies and group of companies with related party transactions are affected by transfer pricing rules.

Peter Dachs The issue arises as to whether a foreign company is required to submit an income tax return. In this regard section 67(1) of the Income Tax Act provides that every person who at any time becomes liable for any normal tax or who becomes liable to submit any return contemplated in section 66 must apply to the Commissioner to be registered as a taxpayer.

Alvaro de la Cueva Under Spanish tax law, corporate income taxpayers that realise a gain on the sale of a holding of more than 5% in a resident entity in Spain are entitled, provided the holding has been owned for more than one year, to take a corporate income tax credit equal to the portion of the gain that relates to the reserves of the investee that have already been taxed at the investee. However this mechanism, which aims to eliminate the double taxation that would arise if the income was first taxed at the investee and then on the occasion of the gain, is not reflected in the non-residents income tax.

A monthly commentary on the notable facts, figures and goings-on in the tax world.

Tim Stewart Vinelight Nominees Limited v CIR is the New Zealand Court of Appeal's latest decision on the general anti-avoidance rule (GAAR) and the tax resident test for companies. The decision also addresses the time limitation on Inland Revenue's ability to re-assess taxpayers, and a taxpayer's ability to raise new arguments in the course of court proceedings. The case arises from a restructure of a family's investments in 1998, following advice from EY. The family carried on business in New Zealand through Vinelight Investments Limited (VIL), a New Zealand tax resident company. The family also owned Weyand Investments Limited (Weyand), a Hong Kong incorporated company.

Tax departments around the world are facing growing demands to do more with fewer resources. Joel Walters, inbound tax leader for PwC US, explores how in-house teams can successfully navigate the new corporate tax landscape in light of increased scrutiny on tax planning processes, reporting requirements and compliance initiatives.