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Companies with loss-making PEs stand to gain A judgment of the European Court of Justice (ECJ) in a case involving Argenta Spaarbank (Argenta) should benefit Belgian companies with loss-making permanent establishments (PE) in other member states and will impact tax deduction regimes in EU countries.

Jeff Scheine and Gary Gartner, former partners of Kaye Scholer in New York, have left the firm to start Alchemy Capital Planning, a tax planning and business consulting firm aimed at serving international clients looking to invest or expand in the US or globally. Over the past 25 years, they have advised clients on a full-range of tax and business-related issues.

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.

Clint O’Connell When hiring labour in Cambodia, it is essential to know what kind of relationship exists from a tax perspective. Importantly, the General Department of Taxation (GDT) will not base its view simply on the contract or agreement in place, but on the actual facts of the matter. The method and rate of taxation varies for employees and independent contractors – employees will be subject to Tax on Salary (TOS), whereas contractor's fees will be subject to withholding tax. A resident will be subject to monthly deductions of tax withheld from salaries received from both Cambodian and foreign sources (in practice only Cambodian sourced salary can be declared). TOS rates are progressive, ending with a top marginal rate of 20% of the taxable base (see Table 1).

Nélio B Weiss

Bill Maclagan

The United Nations (UN) has released the final version of the Practical Manual on Transfer Pricing for Developing Countries (the UN Manual). Vatika Bhatnagar, of Airtel India Limited, examines the Manual’s India chapter, which covers the key issues faced by taxpayers in the country.

India’s Ministry of Finance has been upping its efforts to lure foreign investors by reassuring them the country’s tax regime is not unfairly targeting foreign multinationals. It is even going to the trouble of holding a weekly audience for taxpayers. But have multinationals heard this all before? Joe Dalton discovers why tax directors remain wary when they hear the Indian government make tax promises, and what measures might restore their confidence.

In 1969, 10 countries imposed some type of indirect tax. Today, indirect tax is prolific. More than 160 countries have, plan to have, or are considering some form of indirect tax. Gary Harley, head of indirect tax at KPMG in the UK, explores the rise of indirect taxation.