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Sean Foley

David Cuellar

Sead Dado Salkovic According to the Montenegrin Corporate Profit Tax Law (the law), a resident taxpayer who generates profit outside the territory of Montenegro and pays a tax on those profits in another country shall be granted a tax credit in Montenegro equal to the amount of the tax paid in that other country. However, this tax credit cannot exceed the amount that would be calculated by applying the provision of Montenegrin Law on income earned in another country. In line with the above, a tax treaty on elimination of double taxation that is in force, which Montenegro has signed with a certain country, has a legal supremacy over the provisions of the law. To exercise the right under a treaty concerning the tax credit, the company must have a certificate of residence which is issued by the competent tax authority. The form and content of the certificates of residence, for tax purposes, is regulated by the Montenegrin Ministry of Finance.

Argentinian lawyer, Guillermo Teijeiro, has launched a new firm. Teijeiro & Ballone Abogados will be based in Buenos Aires and Teijeiro brings with him a number of colleagues from his former firm Negri & Teijeiro, which Teijeiro founded more than 30 years ago.

Deloitte has a new head of its tax management consulting practice in the US.

David Blair David Fischer Crowell & Moring is strengthening its tax practice with the arrival of two tax controversy and litigation partners in Washington, DC. David Blair joins from Miller & Chevalier, while David Fischer joins from Cooley. The pair collectively bring more than half a century of litigation, trial and advisory experience with them. Blair is a former trial attorney for the tax division of the US Department of Justice and has experience in handling tax litigation and controversy matters in the areas of transfer pricing, foreign tax credits, partnerships, tax treaties, and tax accounting issues, among others.

Several recommendations have been agreed Taxpayers can look forward to earlier, more cost effective dispute resolution after the Australian Taxation Office (ATO) agreed to several recommendations in a recent report published by the Inspector-General of Taxation (IGT). The IGT's Review into the ATO's use of early and Alternative Dispute Resolution highlighted taxpayers' views that the vast majority of disputes could be resolved without resorting to objection and litigation procedures.

The Treasury is now inviting stakeholder comments on the revised draft

When Goldman Sachs economist Jim O’Neill coined the BRIC acronym in 2001, his new term was born out of a desire to group together those countries viewed as emerging growth markets. The grouping worked because it was clear these countries shared common features, which marked them apart from the rest of the world. That being the case, it is no surprise that the tax structures employed in these countries often need to be different from those used elsewhere. Matthew Gilleard talks to taxpayers and advisers about such structures, what the common mistakes are, and what taxpayers can and cannot do, as compared to tax rules elsewhere.