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Sead Dado Salkovic, Eurofast Global A new regulation about procedures for issuing the Certificate of Residency for the use of the provisions and tax benefits resulting from double tax treaties (DTTs), is effective from August 8 2012. The Montenegrin Ministry of Finance is responsible for the content, the form and issuing of the certificate. The main provisions of this regulation are:

Rajendra Nayak

Michael Solomon and Victor Ng of Fenwick & West discuss two US judgments concerning R&D claims made by Union Carbide, and what taxpayers need to know about claiming credits for supply costs.

The interaction of Poland’s transfer pricing rules and reimbursement law means the pharmaceutical industry is faced with complex compliance demands, explains Aneta Blazejewska-Gaczynska and Slawomir Buszko of Ernst & Young.

See who has done the tax work on this month’s biggest deals.

Padraic Fallon Padraic Fallon, chairman of Euromoney Institutional Investor PLC, which publishes International Tax Review, died in October at the age of 66.

Alberto Lissi Tax Partner – Taxand has hired a new partner from the Swiss practice of a big-four firm. Alberto Lissi, formerly responsible for Ernst & Young's banking tax practice in Switzerland, moved to Tax Partner – Taxand in September 2012. He has more than 14 years of national and international tax experience.

Cross-border transactions and interpretation of related international tax treaties often involves controversies and issues concerning interpretation of treaty provisions and thereby leads to litigation with tax authorities. A recent judgment of the Tax Tribunal (Tribunal) in India in the case of Apollo Hospital Enterprises Limited (AHEL), has given rise to a debate regarding the interpretation of the expression “may be taxed” used in the India – Sri Lanka double taxation avoidance agreement (Treaty). Sanjay Sanghvi and Ashish Mehta, of Khaitan & Co, explore the implications.

New Zealand taxpayers are watching Alesco's Court of Appeal case with bated breath, as the outcome could give a big indication of the extent to which the country's general anti-avoidance rule (GAAR) can be invoked against transactions.

Marco Pace KPMG in the US has boosted its economic and valuation services practice by hiring Marco Pace. Pace has returned to KPMG as a principal in the firm's Economic and Valuation Services (EVS) practice, and will be based in New York for the new role.