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  • Eylem Philippou Drilona Likaj The income tax treaty that was signed back in October 2009 for the avoidance of double taxation and prevention of fiscal evasion between Albania and Ireland entered into force on July 12 2011 and will be applicable from January 1 2012.
  • Piet Vandendriessche and Nigel Mellor of Deloitte find that while VAT in the US is still unlikely soon, taxpayers should be alert to the possibility.
  • Clemens Fuest has identified six objectives for the FTT
  • The Finnish Central Tax Board (CTB) has given a preliminary ruling (KVL 34/2011) regarding taxation in connection with transfers of investments in life insurance saving agreement and capitalisation agreement where the taxpayer has the right to decide on which assets the policy funds are invested in.
  • Renata Dluska The amended CIT Act imposed new documentation requirements on payments of income to foreign entities that seek tax exemptions. Under the new rules, the following documents will be required:
  • Elena Kostovska In April, FYR Macedonia signed a treaty for the avoidance of double taxation with its newest neighboring state, Kosovo. The two countries have recently made steps toward boosting the cross-border economic cooperation, with multiple joint projects, activities as well as meetings between the chambers of commerce. In 2010, the total exchange between the two countries increased by 41% and FYR Macedonia's exports to Kosovo are estimated at a significant amount of $300 million.
  • Wiwin Siswanti The Directorate General of Taxes (DGT) of Indonesia has issued two regulations regarding the settlement of transfer pricing disputes, namely, PER-69/PJ/2010 regarding advance pricing agreement (APA) and PER-48/PJ/2010 regarding mutual agreement procedure (MAP).
  • Bob van der Made A single European market in the area of taxation still does not exist. In practice, this means that multinational corporations doing business in the EU need to navigate their way through (up to) 27 different national tax administrations and administrative requirements, and widely differing national interpretations of EU tax law, directives and regulations. But Europe's direct tax policy landscape is changing fast and in a fundamental way as a result of the growing economic and political pressures to manage and find a sustainable solution out of the financial and economic crisis. Highly controversial EU policy options which were previously unthinkable are now tabled. Marked examples are the European Commission's proposals for a common consolidated corporate tax base (CCCTB) and a financial transaction tax (FTT), as well as the relatively quickly adopted EU "six-pack" proposals on financial sector regulation.
  • Giannos Ioannou Georgia Papa The first package of austerity measures was voted by the House of Representatives on August 26 2011. The measures intend to assist Cyprus in reducing expenditure while increasing revenue and at the same time maintaining Cyprus's reputation as a stable and competitive financial centre. The changes entail amendments to various laws, including amendments to the immovable property tax whereas a second and most likely a third package of further financial changes is expected in subsequent months.
  • Nélio Weiss Philippe Jeffrey As widely known, Brazil's transfer pricing rules do not adopt the internationally accepted arm's-length standard. For instance, for the purposes of applying the Brazilian equivalent to the resale price method (PRL) in transactions involving import of goods between related parties abroad, regulations provide the use of statutory fixed margins to derive a benchmark ceiling price. In these instances, actual transfer pricing practiced by the local tested party must be lower than that derived benchmark price, otherwise tax authorities will impose a transfer pricing adjustment.