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Jim Fuller

Thuan Pham The Vietnamese tax authorities have conducted a number of tax audits focusing on transfer pricing abuses in recent years, including by companies with foreign investment. While no definitive judgments have been issued, several companies are suspected of having abused the transfer pricing regulations and committing tax evasion. In an effort to reduce tax evasion and tax fraud, and to achieve efficient tax governance, an amendment to the Law on Tax Governance was introduced on November 20 2012, along with the introduction of an advance pricing agreement (APA) programme, with the aim of providing taxpayers and tax authorities with tax certainty, transfer pricing planning, protection from tax evasion, and tax efficient management.

Rajendra Nayak

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

Brendan Brown

Read this month's special features on Brazil and Asia.

Hans Rudolf Habermacher