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Through its inclusion in the CIVET (Colombia, Indonesia, Vietnam, Egypt and Turkey) group of countries, Vietnam is being touted as one of the world’s most attractive future investment locations for multinationals and the country’s government is rapidly trying to align its tax system with those of developed countries.

A monthly commentary on the notable facts, figures and goings-on in the tax world.

Fernando Castro Silva

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".

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:

David Cuellar

Keith O’Donnell

Daniel Harrison The Ministry of Finance has issued Notification No. 3086/MoF, dated March 19 2013 on tax registration and renewal in light of the introduction of the one-stop service under the current investment regulations. Following on from the issuance of Decision No. 2411/MPI, dated October 7 2011 regarding the organisation and activities of the One-Stop Investment Office (One-Stop Office), the Notification comes as a consequence of guidelines for the one-stop service not being able to be issued on a timely basis.

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.

Eleonora Briolini Eleonora Briolini, the head of tax for Bird & Bird in Milan, has become a partner of the firm, which she joined in January 2012 from Studio Tributario e Societario Deloitte. She advises clients on the international tax planning aspects of project financing, debt restructuring, and acquisitions, as well as post-acquisition tax integration projects, due diligence and modelling.