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Gerry Thornton

While many countries, such as the UK, actively try to attract investment by promoting an open for business agenda epitomised by offering attractive tax benefits such as a competitive corporate income tax rate and a patent box scheme, the BRICs countries – and Brazil in particular – are managing to attract investment in spite of their unattractive and complex tax regimes. Matthew Gilleard finds out why.

Elena Kostovska According to Article 56 of the Law on VAT in FYR Macedonia, the Public Revenue Office (PRO) is empowered to – at its discretion – register two or more legal entities as VAT-dependent or VAT-related taxpayers. The basis for such a joint VAT registration is the existence of certain ownership, organisation or management relationships between the entities as well as PRO's view of whether such relations may lead to a misuse or breach of the national tax laws. On the other hand, the practice has given us sufficient evidence that related entities voluntarily register as related VAT payers to take advantage of the monthly tax period which is mandatory for such group-payers.

David Cuellar

Cynthia Herman Despite widespread rumors to the contrary, the award of telecommunication licences was announced right on schedule on June 27 2013, following weeks of build-up. The two selected from the final shortlist of 11 bidders – Telenor, the Norwegian company, and Qatari Ooredoo – are set to roll out their networks in a race for the largest market share and in an effort to radically improve the mobile coverage of Myanmar. It is likely that the operators will be subject to the same Income Tax regime, including available tax incentives. Both newly licensed operators are applying for an investment permit from the Myanmar Investment Commission (MIC) which under the Foreign Investment Law 2012 (FIL) grants an automatic five year income tax holiday, which may in some cases be extended. After this holiday, a 25% corporate income tax rate applies to net profit.

Peter Dachs This Bill contains many significant amendments to South Africa's tax laws. In respect of domestic law amendments these include the re-characterisation of interest as dividends in circumstances where the debt on which such interest is paid contains certain equity features. In addition, various limitations on interest deductions will be imposed in respect of acquisition indebtedness as well as loans between exempt persons and South African resident companies.

Jorge Moreira It is a well-known fact that thousands of European citizens – British, German, Danish, Swedish, among others – choose Spain as their retirement destination, attracted by our weather and the quality of our medical services, after a long working life during which they have managed to amass the savings needed to do so. In many cases, these savings take the form of life insurance/bonds, pension plans and similar products.

Under Australia’s self assessment tax system, effective tax risk management is critical in minimising the likelihood of a tax audit and maximising the chances of a favourable outcome from the ensuing investigation. Paul Sokolowski and Clint Harding, of Arnold Bloch Leibler, explain how taxpayers should manage an Australian Taxation Office (ATO) audit to give themselves the best chance of a positive outcome.

Dorina Asllani Ndreka, Eurofast Global Taxpayers in Albania have the right of appeal to: a tax assessment notice; decisions that affect the taxpayer's obligation on any claim for refund or tax relief; or to any special tax act connected with the taxpayer's activity. According to tax laws, the tax appeal is held in two legal dimensions, administrative and judicial, which constitute two separate links of the same legal process. Article 106 of Law no.9920, dated May 19 2008 ("On tax procedures"), provides the situation which constitutes grounds for appeal and the competent authority to whom the appeal must be filed initially. The appeal is submitted in writing to the Directorate of Tax Appeals, within 30 days from the date of the relevant administrative act.

Germany remains concerned about the competitive disadvantage it feels it is being placed under by the existence of European patent box regimes such as the UK Patent Box and the Dutch Innovation Box. German Finance Minister Wolfgang Schaeuble has said that such tax breaks for patents (the UK regime allows for a reduced 10% tax rate for income derived from UK or European patents held in the UK, for instance) do not respect the spirit of EU anti-discriminatory rules.