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Elena Kostovska As of January 1 2013, the Law on Lawyer Stamps (effective as of July 2012) entered into force but is under review of the Constitutional Court following an avalanche of criticism from lawyers across the Republic. According to the law, FYR Macedonian lawyers who earn income in cash are now required to attach the lawyer stamps to each document/form they submit to the authorities in FYR Macedonia. The lawyer stamps are issued by the Public Revenue Office on the basis of an application from a lawyer. Subject to this law are all attorneys registered in the FYR Macedonian Bar Association and who provide legal services as physical persons-lawyers and not to those working within a legal entity – law firm. Such individual lawyers are now obliged to keep records of the used attorney's stamps and to submit the newly introduced E-AM form to the Public Revenue Office by January 31 of the following year.

Fernando Castro Silva

Gordana Vucenovic In January 2013, the double tax treaty (DTT) with respect to taxes on income and capital between Serbia and the United Arab Emirates was signed and on March 15 2013 the Parliament of Serbia ratified the treaty. The permanent establishment (PE) is considered as the fixed place of business such as a place of management, branch, office, factory, workshop, mine, oil or gas well. The term also includes:

Peter Dachs The 2013 budget which was released on February 27 2013 included various interesting proposals in relation to cross border transactions. It is proposed that the taxation relating to trusts in South Africa will be amended. As part of this process it is proposed that distributions from offshore foundations will be treated as ordinary revenue in the hands of South African residents. It is stated that "this amendment targets schemes designed to shield income from global taxation".

Keith O’Donnell

David Cuellar

Jonathan Hornby Alvarez & Marsal Taxand UK has appointed two new managing directors in London. Charles Beer joins the firm from KPMG, while Jonathan Hornby is promoted from the position of senior director.

Kalpesh Desai has been promoted to partner at BMR Advisors in Mumbai.

The increasing sophistication of transactions performed between taxpayers has raised concerns among legislators about the recurrent manipulation of the terms and conditions of such transactions as a way of reducing the tax impacts, thus distorting the objectives of the tax systems. Rui Guedes Henriques, Tiago Almeida Veloso and Ana Filipa Janine of Baker Tilly look at the VAT anti-abuse rules introduced in the 2012 budget to address these concerns.

Jens Wittendorf, of Deloitte Denmark, examines a recent dispute in the National Tax Tribunal (NTT) which highlights how unilateral anti-hybrid legislation can have the unintended consequence of eroding the domestic tax base.