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Elena Kostovska In late June 2012, an amended Law on Tax Procedure was adopted in the FYR Macedonian Parliament. The last time this Law was amended was in the middle of 2011 with certain changes regarding the appeal procedures. This latest set of changes was suggested by the Ministry of Finance in an attempt to clarify certain aspects related to the procedure of tax control that were previously ambiguous. With the amendments, it is now stipulated that the tax authorities can perform unannounced tax audits on the premises of the taxpayer without previous notice should they need to obtain certain information that may have been requested by a foreign tax authority.

Bryan Bailey

Sandra Fleurier

Luis Viñuales

Brad Rolph of Charles River Associates in Canada takes a closer look at the memorandum of understanding (MOU) on arbitration between the US and Canada and the accompanying arbitration board operating guidelines. He also examines whether the arbitration procedure is accomplishing its objectives to reduce the amount of time it takes to resolve double taxation cases and increase the use of principle-based negotiating positions.

Andrés Edelstein

Dajana Topic The tax treaty between Bosnia & Herzegovina (B&H) and Kuwait concluded on October 28 2008 for the avoidance of double taxation and the prevention of fiscal evasion related to income and capital was ratified by the B&H Parliament on December 28 2011. In the case of B&H, the treaty covers the income tax, profit tax and tax on capital. On the other hand, in the case of Kuwait the treaty covers corporate income tax, the contribution from the net profits of the Kuwaiti shareholding companies payable to the Kuwait Foundation for Advancement of Science (KFAS), the Zakat and the tax subjected according to the supporting of national employee law.

Frank Gehring

Peter Dachs The draft Taxation Laws Amendment Bill, 2012 which was released by National Treasury on July 6 2012 proposes to amend, inter alia, the interest exemption contained in section 10(1)(h) of the Income Tax Act as from January 1 2013, as well as the interest withholding tax provisions which will come into effect on January 1 2013. The proposed amendments will likely have an effect on the taxation of interest payments made from January 1 2013 in respect of certain debt instruments / notes issued by resident issuers to non-resident holders.

Zeki Gündüz