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Rossitza Koleva Sophie Stylianou A wide range of double tax treaties have been concluded by Bulgaria in an attempt to strengthen the country's ties internationally and achieve a higher foreign direct investment rate in the country. Equally, existing treaties have been revised allowing for more attractive tax rates with respect to specific income deriving from either one of the participating states.

Sophie Stylianou Financial structuring and restructuring within a group has always been of utmost importance in the course of tax structuring. Financial transactions and corporate capitalisation matters have triggered the interest and consideration not only of investors and tax advisors, but also of the tax authorities globally. In the absence of uniform international guidelines and standards, every country adopts different measures seeking to mitigate abuse of law and financial transactions between related parties. Some countries apply thin capitalisation rules with strict debt-to-equity restrictions, others enforce preventive withholding taxes, and others adopt safe harbour rules.

The tax authorities in the UK are looking at the effectiveness of ADR to resolve tax disputes. Lessons can be learnt from other jurisdictions who have previously implemented schemes, says Richard Doran of Dorsey & Whitney

Loreto Pelegrí H Rodrigo Winter S Chilean Income Tax Law provides that interest payments by a Chilean resident to a foreign person are subject to a 35% withholding tax. The rate is reduced to 4% in the case of interest arising from loans granted by foreign or international banks or financial institutions, or interest arising from amounts outstanding that result from the import of goods under the deferred coverage system and from bonds or debentures in foreign or local currency.

Ian Farmer On May 2 2010, the Australian Government released the Henry Review into Australia's tax and transfer system, which it commissioned almost two years ago. More importantly it also released its response to the Henry Review which it was hoped would set out a blueprint for tax reform for the foreseeable future in Australia.

Alexander Wiedow: Energy Taxation Directive is largely being used as a means to attract revenue, rather than combat climate change Speakers at International Tax Review's indirect tax forum in London on June 16 criticised the EU for failing to ensure its environment taxation policy met its objectives.

Peter Dachs Under South African domestic tax law, non-residents are exempt from South African tax on interest earned on debt instruments. However from March 1 2011 such interest will be taxable in South Africa in the hands of such non-residents. This is due to a proposed law change contained in the Draft Taxation Laws Amendment Bill due for promulgation later this year.

When the US Congress codified the long-standing common law doctrine known as economic substance, many tax practitioners were not shy about criticising the move, expressing concern about the effects of this new law on corporate tax planning. Erin Kelechava spoke to tax lawyers, professors, and policy experts and found out that a statute that was meant to clarify what an abusive transaction is may end up achieving the opposite result.

Vladimir Kotenko On June 16 2010 Law No 2275 became effective, introducing rather controversial amendments to a number of tax laws, including:

Chinapat Visuttipat On June 2 2010, the Thai cabinet released its resolution to improve Thai tax laws in relation to Regional Operating Headquarters (ROH) with the aim of achieving the best tax incentives in the region.