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Jim Fuller

Sean Foley

Peter Dachs The Taxation Laws Amendment Act 2012 contains various legislative amendments to the Income Tax Act which have retrospective effect. There is a general presumption in South African law that legislation is not intended to operate retroactively, or with retrospective effect, because to hold otherwise might cause great injustice to the individual.

Elena Kostovska Because of the private sector's low liquidity as a result of the global financial downturn, companies frequently find themselves reaching for the last available tool to collect uncollected receivables, the forceful collection mechanism. It is worth noting that the procedure to forcefully collect outstanding debt is regulated by certain deadlines after which the said debt becomes obsolete; therefore is considered a bad debt. The following information is of interest to creditors in the private sectors as well as tax debtors that have outstanding liabilities towards the Public Revenue Office in FYR Macedonia.

Thuan Pham Vietnam is a country with a high volume of imports and exports, many of which are transported by sea. For this reason, most of the leading international shipping lines have been present in Vietnam for years via shipping agencies, forwarding agents and other commercial representatives. Vietnam's income tax regulations impose tax on foreign carriers for outbound transactions only. In addition, most of Vietnam's double taxation agreements (DTAs) have a clause on international traffic that gives the right to tax to the home country where the carrier is a resident. Given this, it seems that most foreign carriers should be exempt from tax in Vietnam on the income generated from international ocean traffic. However, the complexity of international transportation activities and a cumbersome process to apply for DTA exemption discourage many taxpayers from taking advantage of this benefit. There is often a long waiting period while the tax authority assesses the dossiers and comes to a final decision regarding DTA exemption. Now, in an effort to simplify the DTA notification process and assist taxpayers (ocean carriers) with tax treaty benefits, the Ministry of Finance (MOF) has drafted an official ruling for collection of opinions from experts.

Vincent Lacombe, Laëtitia Banos and François Garcia, of FIDAL Direction Internationale, analyse the proposed changes to the French audit system and present the initial reactions of French tax directors to the concept of a trust-based relationship with the tax administration.

Fulvia Astolfi and Vito Vittore of Hogan Lovells analyse Italy's new financial transaction tax (FTT).

Dajana Topic A country's fiscal system is the complete setup of government revenue and expenditures and the way in which government agencies carry them out. This system is governed by fiscal policy, which comes from decisions made by the governing body. The law on fiscal systems in the Republika Srpska came into effect at the end of 2008. While the first deadline for fiscalisation and putting into operation the fiscal record turnover in the Federation was the end of 2010.

Tax litigation and controversy specialist Steven Dixon has been elected as a new member in Miller & Chevalier's Washington, DC office.

Tax heads of multinational companies say the UK Supreme Court's decision in the Prudential case, which said legal advice privilege (LAP) only protects communications between taxpayers and lawyers, will not make them choose lawyers above accountants for tax legal advice.