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Elena Kostovska FYR Macedonian companies choosing to distribute free promotional material (branded giveaways) to individuals or other businesses often have to deal with the rather narrow VAT treatment of such expenses in the framework of the FYR Macedonian tax system. The local legislation gives very limited (almost none whatsoever) opportunities for tax exemptions for promotional giveaway expenses.

Sead Dado Salkovic International transport such as road, rail, shipping and air traffic is one of the main aspects of most economic cooperation.

BIAC, the Business and Industry Advisory Committee to the OECD, is more active than ever in the organisation’s 50th year. As Sophie Ashley discovers, balancing industry’s needs against a sustainable future and combining a need for effective communication against individual agendas is all in a day’s work for Chris Lenon, chairman of BIAC’s tax and fiscal policy committee.

Rajendra Nayak Ganesh Pai The Calcutta High Court in the case of ABN Amro Bank NV (Taxpayer) [2011-TII-09-HC-KOL-INTL], adjudicated on certain tax related aspects of transactions between a branch office (BO) and its head office (HO)/taxpayer. The taxpayer, a Netherlands company, undertakes banking activities in India through various branches, with its principal branch located in Kolkata, India (Indian branch). The Indian branch made interest payments to the HO in respect of deposits placed/money lent by the HO with the BO. International tax principles generally require that while attributing profits to a permanent establishment (PE)/BO, the HO and the BO are to be hypothetically treated as separate and distinct enterprises while dealing with this question (separate entity approach). This approach raises questions on issues relating to tax deductibility of payments and taxability of recipients between the hypothesided enterprises. The India-Netherlands tax treaty also requires a similar approach while determining the attributable profits of the PE. The issues before the court were the taxability of interest payments made by the BO to its HO and the deductibility of the corresponding expenses incurred by the BO on such payments.

Janne Juusela The Finnish Supreme Administrative Court decided on March 7 2011 (KHO 2011:21) to request for a preliminary ruling from the ECJ concerning the question whether a Finnish parent company may deduct the final tax losses of its Swedish subsidiary after a cross-border merger.

The UK Court of Appeal has unanimously reversed the High Court's decision in favour of the taxpayer in the Bayfine v HM Revenue & Customs (HMRC) case.

Law firm Berwin Leighton Paisner, headquartered in London, has appointed senior associate Richard Harbot as a partner in the tax practice.

Deloitte has announced that former tax partner Barry Salzberg has been chosen to take over the position of global chief executive officer. Salzberg will replace Jim Quigley, who has completed his term, from June 1 2011.

Steve Snyder has joined the Atlanta office of PwC in the transfer pricing controversy practice.

Natasha Mavrommati Cyprus further expanded its trade relations with the Middle East by signing an income tax treaty with the United Arab Emirates on February 27 2011 in Abu Dhabi.