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Sead Dado Salkovic Slobodan Mihajlovic The tax treaty on avoidance of double taxation of income and capital signed on February 5 2008 between Spain and Bosnia and Herzegovina came effective on January 4 2011. The treaty applies to residents of one or both contracting states and covers the taxation of personal income, corporate profit, non-resident income, property tax, local taxes on income and property in Spain and profit, personal income tax and property tax in B&H.

Sabrina Wong Josh Jones Foreign entities considering how to access excess funds in their Canadian subsidiaries without triggering adverse Canadian tax consequences may want to utilise the financing strategies used in three recent Canada Revenue Agency (CRA) rulings.

Paul Mulvihill, Fred O’Riordan and Steven Wrappe of Ernst & Young discuss the recently issued guidance on the arbitration process in the fifth protocol to the US-Canada tax convention and discover that taxpayers will benefit from greater confidence and certainty from the changes.

Jose Miguel Barragan joined the tax practice of Jones Day in Mexico City on February 1 2011.

The Singapore Court of Appeal has issued a ruling that will assist taxpayers in determining whether an asset constitutes a plant when making a capital allowance claim.

A monthly commentary on the notable facts, figures and goings-on in the tax world. Suitable items should be sent to taxrelief@euromoneyplc.com

Sean Foley Landon McGrew The Obama administration recently released a number of international tax proposals as part of its annual budget for FY2012. On the same day that the President's budget was released, the US Treasury Department released its Green Book, which provides detailed descriptions of the administration's budget proposals. In general, this year's international tax proposals are the same as those included in last year's budget, with the exception of the FY 2011 proposals that were enacted last year. If enacted, the administration projects that this year's international tax proposals will raise approximately $129 billion over the next 10 years. The proposed effective date for items included in the FY2012 budget is for taxable years beginning after December 31 2011.

Ronald Parks The Vietnamese government recently implemented what appears to be a fragmented series of gold-related policies. The policies focus on three main elements: import quotas, export tax and banking. The results of these recent changes highlight the risk of tax planning in Vietnam if considered in a vacuum.

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

Oleh Marchenko highlights a new trend in the Ukraine: customs authorities are beginning to examine intercompany transactions with increasing levels of scrutiny.