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Donka Pechilkova From this year, the final tax rate on online bets, which the State Commission on Gambling in Bulgaria legalised in late 2012, is 15%. Originally the cabinet proposed a much lower rate, 7%, for the online gambling operators with the assumption to attract major international bookmakers to the Bulgarian market, but finally adopted the same 15% tax rate for both traditional and online gambling which will come into effect in 2013. The licensing of the organisers of gambling is now mandatory, and those who do not have the license will be black-listed, the Bulgarian players will not be allowed access to their sites, as the access will be governed by the internet service providers (ISP). This amendment expected to legalise the activity of the online gambling games organisers. Thus, this environment will contribute to the development of long term activities in the Bulgarian market on behalf of the operators, and on the other hand the consumers will have the guarantee that the sites in which they deposit their money will not speculate with them, will not prove to be phantom sites as their activity will have the regulative law frame.

Jacques Taquet

On March 7 2013, Greek Law 4132/2013 introduced a special regime for suspension of the requirement to pay VAT upon importation of non-excisable goods by foreign taxable persons having a VAT registration number in Greece. This applies to the extent that such goods are mainly used for exports to third countries or intra-EU deliveries to EU countries. Practically this introduces a deferral of payment of import VAT; while import VAT shall be assessed on the customs documents upon importation, the importer will account for this VAT on their periodic VAT return. To take advantage of this regime, a foreign taxable person intending to act as importer of record in Greece should apply in advance to the Greek Ministry of Finance to obtain a state license. The license shall be granted providing the following conditions are cumulatively met:

Giuliano Foglia

Ingunn Mollnes Norway's Ministry of Finance released a consultation paper on April 11 2013 that would introduce limits on the deduction of interest on related-party debt. The purpose of the proposal is to restrict earnings stripping via intercompany debt financing. Under the proposal, net interest expense paid to a related party would not be deductible in a year to the extent such expense exceeds 25% of a basis of limitation, a figure similar to EBITDA. The limitation would be calculated separately for each entity. However, the limitation only applies to companies that have net interest costs exceeding NOK1 million ($170,000). The proposal suggests that the rules would apply as from fiscal year 2014.

India’s tax authority has filed a special leave petition with the Supreme Court attempting to overturn the High Court’s ruling in the Sanofi case, and is also asking the court to reassess the principles set down in its Vodafone judgment.

The Irish Revenue Commissioners are in the market for more corporate databases through which they can evaluate companies’ transfer pricing more effectively.

More Spanish companies are receiving financial assistance through related party loans due to greater bank restrictions on corporate loans, advisers say.

In the last of his four-part series for International Tax Review, Donald Bowman QC, former Chief Justice of the Tax Court of Canada, now counsel to Dentons’ national tax group, examines the increased use of expert testimony in disputes involving R&D tax credits.

Energy groups with petroleum projects in Australia need to change the way they document expenditure to ensure they can successfully substantiate exploration expense deductions, following a judgment published by the country’s Administrative Appeals Tribunal (AAT) yesterday.