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Janne Juusela Amendments to the regulations concerning the taxation of share exchanges have been proposed in a recent government bill. The amendments are expected to be applicable for the first time in the assessment of tax year 2012. Due to the extension of the time limit, the amendments would be applicable to share exchange arrangements which have taken place after January 1 2009.

Rudina Hoxha, Eurofast Global Based on the dispositions of the Law no. 9920, dated May 19 2008, on "Tax Procedures in the Republic of Albania", and the Law no. 9632, dated October 30 2006, on the "Local Tax System", the General Directorate of Local Taxes has published a website www.dpttv.gov.al, which is a portal for each entity to access information on the local tax liabilities for the fiscal year 2012.

Recent guidance provides temporary relief to non-US persons that invest in US equity derivatives, but proposed rules may lead to some harsh consequences, warn Julio Castro and Taylor Romigh of Dewey & LeBoeuf.

A financial transaction tax seems certain to be introduced, if not across the EU, then in individual member states. However, Philip Martin, formerly co-head of tax at Nomura, does not believe it will raise the revenue envisioned by its designers or lead to more market stability.

Hong Kong’s Commissioner of Inland Revenue (CIR) announced during a public seminar in February 2012 that the Inland Revenue Department (IRD) is preparing to launch an advance pricing arrangement (APA) programme starting in April 2012. Philip Wong and Petrina Chang of Deloitte in Hong Kong provide a break-down of the new facility.

For the past three years, Indonesian taxpayers have been facing more challenges from the Directorate General of Taxes (DGT) regarding their related-party transactions. The areas of dispute are various; common challenges from the DGT are on management service fees, cost allocation, royalty fees, purchases of raw materials, sales of goods, and sales of capital goods. Permana Adi Saputra, of PB Taxand, describes the new regulations and how they will affect taxpayers.

When allocating corporate costs for intra-group services, the Norwegian Tax Authorities has in recent years been claiming that allocations based on opex/capex must be adjusted for local price- and cost levels by applying a price level indicator (PLI). Jan Jansen and Joachim Bjerke of BA-HR explain what this means for the Norwegian energy sector.

Mauricio Valenzuela

Khoonming Ho

Panayiotis Diallinas According to Article 6 of the Law on Foreign Exchange operations, offsetting of payables and receivables between resident and non-resident entities is regulated by the Ministry of Finance in cooperation with the National Bank of Serbia. However, the aforementioned offsetting operations between residents and non-residents were not legally regulated until the government of Republic of Serbia adopted the decree on conditions and methods for offsetting payables against receivables involving foreign currency loan operations with foreign countries (the decree), as recommended by the National Bank of Serbia and published on Official Gazette No. 99/11. The decree was effective on January 4 2012.