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Clint O’Connell When it comes to offices, retail and factories in Cambodia, most often the lease agreement is concluded between two Cambodian corporate entities. The landlord could be a property development/investment company and the tenant is usually a corporate entity as well. In Cambodia, a unique set of tax obligations, in terms of VAT and withholding taxes, applies to the rental payments. In some extreme cases, unforeseen tax implications can render the project uneconomical.

Bob van der Made After the European Commission presented its draft Directive for the financial transaction tax (FTT) to the European Council on February 14 2013 under the EU's enhanced cooperation procedure, the national fiscal attachés of the 27 EU member states started a series of technical discussions in the Council Working Party on Tax Questions – Indirect Taxation under the Irish EU Presidency on February 21 2013. This process is referred to as article-by-article reading or first reading whereby the fiscal attachés go through the Directive chronologically and can propose amendments. They can also ask the Commission, which is present throughout, as the proposer of the EU legal act, to clarify the articles and their impact further.

Nélio B Weiss

Donka Pechilkova New rules for administrative cooperation between EU member states have been required to respond to the challenges of globalisation. This type of assistance in the field of direct taxation has been established since 1977. At that time the cooperation was regulated by Council Directive 77/799/EC. That initial directive was replaced with Council Directive 2011/16/EU.

Type of Agreement Country Country Date Signed Double Taxation Avoidance Agreement Poland US June 24 2013 (Ratified)

The political momentum for changing the international tax system has never been greater. The OECD’s work on issues concerning base erosion and profit shifting (BEPS) has been thrust firmly into the spotlight. As we await the organisation’s roadmap on addressing BEPS in July, Joe Dalton asks stakeholders on all sides of the debate: how should the international tax system be fixed, and what are the consequences for the multinationals operating within it?

Michael Lennard, acting secretary, UN Committee of Experts on International Cooperation in Tax Matters, writing in a personal capacity, discusses the UN Practical Transfer Pricing Manual for Developing Countries, which was publicly launched on May 29.

Cagla Bekbolet runs the financial officers’ practice at global executive search firm Egon Zehnder. Multinationals who use her to find their next tax director are, more and more, looking for a new kind of professional who can deal with the challenges presented by the demand for increased transparency and the need for the management of a company’s tax affairs to enhance, or at least, not harm, its reputation. Salman Shaheen speaks to Bekbolet to find out what new skills are needed and where they can be found.

Jim Fuller

Gordana Vucenovic At the beginning of May, Mladjan Dinkic, the Serbian Minister of Economy, announced that the government proposes the following changes in the area of income taxation: Decrease of payroll taxes from 12% to 10%; Increase of pension contributions from 22% to 24%; and Increase in the limit of flat tax from RSD 3 million ($34,590) to RSD 6 million. The changes are designed to benefit crafters and small and medium enterprises by increasing the limit for taxation.