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In an effort to raise tax revenues and reduce the budget deficit, in the past 12 months the Spanish government has introduced several far-reaching tax measures, affecting virtually all the taxes applicable to large businesses or individuals. Vicente Bootello and Álvaro de la Cueva of Garrigues analyse the changes.

Joe Dalton examines the tax regimes of the CIVETs countries to discover whether they truly constitute attractive and secure future investment destinations for multinationals, or if the term is simply another economist’s efforts to jump on the acronym bandwagon.

How to organise your tax affairs across the BRICS nations.

Proposed Indian general anti-avoidance rules (GAAR) were not met with much support when details were revealed earlier this year. But a recent consultation period has brought transparency and clarity to proposal, much to the benefit of taxpayers explains Rajendra Nayak of Ernst & Young.

As transfer pricing enforcement evolves, the State Administration of Taxation (SAT) in China has developed the concept of anti-avoidance tax system combining management, service and investigation. Wu Duo and Li Ying of Siemens in China discuss the merits of transfer pricing investigation versus self-inspection.

Khoonming Ho

Balazs Bekes On July 9 2012, the Hungarian Parliament voted on the financial transaction tax, which will be introduced as of January 1 2013. The new tax will apply to financial service providers with a seat or a site in Hungary, to the postal accounting centre, and, in some cases, to the Hungarian National Bank. Money transfers, collections, payments initiated by way of the beneficiary, cash disbursements, cash transfers payments, redemptions of letters of credits and checks, and central bank deposits made for a time period of between one day and two weeks will be covered by the new transaction tax.

Bob van der Made The European Commission (Commission) held a public consultation on double non-taxation from February 29 2012 to May 30 2012. The contributions and a summary report were published on the Commission's website in the first week of July. In mid-June the Commission invited these contributors from the academic world, non-government organisations (NGO), governments and business groups to a Commission seminar on non-cooperative tax jurisdictions, aggressive tax planning, tax fraud and tax evasion on July 17 in Brussels. On June 27, the Commission published a communication on concrete ways to reinforce the fight against tax fraud and tax evasion including in relation to third countries, to be considered only two days later at the EU leaders' summit. EU leaders concluded that: "The Commission is pursuing work on concrete ways to improve the fight against tax fraud and tax evasion and will soon present an action plan including options to that end." The Commission seminar was used by the Commission to get much needed additional input and information from stakeholders on these diverging notions just before the Commission's planned (compulsory) impact assessment to be done during the summer period. One trend observed during the seminar was the apparent mix-up by non-business participants of the notions of tax evasion, tax fraud, tax optimisation and aggressive tax planning. The lack of clear and generally agreed definitions for these different notions, and/or the use by the EU of too-broad definitions for that matter, was already highlighted by European business groups like EBIT in their submissions to the Commission consultation on double non-taxation as a matter of concern and one which leads to terminological confusion and misunderstandings.

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.

Rajendra Nayak