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  • Anna Pushkaryova On April 23 2015 Georgia and Belarus signed an agreement on avoidance of double taxation, prevention of evasion of income and capital taxes (DTT). The DTT applies to profit tax, income tax and property tax in Georgia and the tax on income, tax on profits, income tax on individuals and tax on immovable property in Belarus.
  • Konstantina Kalakou Recent developments clearly show that the topic of permanent establishment (PE) is high on the Greek tax agenda. As per the practice followed to date by the Greek tax authorities, multinational entities that have a presence in Greece (through a subsidiary) do not often find themselves under the audit microscope provided that the Greek subsidiary has taxable revenues (commonly arising from services that the latter provides to other Group entities). On the other hand, commissionaire structures were scrutinised with the absence of contractual or negotiation authority on behalf of the agent, giving leeway for taxpayers. To this end, a ruling of the Court of Appeal has stated that a Greek agent that has been appointed only for promotion services of the foreign UK entity cannot trigger a PE.
  • Freddy Karyadi Chaterine Tanuwijaya The Indonesian Ministry of Finance has revealed that Indonesia's net tax revenue for 2015 was only IDR1,055 trillion, about 81.5% of the target set out in the 2015 Budget. Although the figure is an all-time high, it still represents a shortfall compared with budgetary projections.
  • Paweł Szymański Effective from February 1 2016, Poland is introducing a new law covering a 'financial institutions tax' (FIT) that will be charged on certain kinds of assets of financial institutions operating in Poland.
  • Victor Adegite of KPMG looks at how the Nigerian Federal Inland Revenue Service has incorporated BEPS Project action points into its transfer pricing audit processes.
  • The UK draft Finance Bill 2016 was published on December 9 2015. Sandy Bhogal, head of tax at Mayer Brown in London, focuses on two topics of particular interest – new rules on taxation of performance-linked rewards for investment managers and new anti-hybrid rules arising out of the OECD’s BEPS Project.
  • Sofia Stavridi, a Queen Mary University of London graduate now working in investment management tax services at a Big 4 firm in the UK, looks at the key BEPS actions impacting the asset management industry.
  • Peter Nias, international tax specialist barrister at Pump Court Tax Chambers in London, analyses trends in international tax dispute resolution, looking at alternative dispute resolution methods and whether the OECD’s recent work in this area represents a missed opportunity.
  • Bob van der Made On January 11 2016, EU Tax Commissioner Moscovici told Members of the European Parliament that: "2016 should be the year of corporate tax reform and fiscal transparency".
  • As developments regarding the OECD’s base erosion and profit shifting project (BEPS Project) continued throughout 2015, the Irish Government continued to be proactive in setting out its tax agenda in the context of the ongoing international tax debate. To strengthen Ireland’s competitive advantage as a destination of choice for investment and to ensure that Ireland remains responsive in this rapidly changing international tax environment, a number of positive developments were announced in 2015, explains Deloitte’s Louise Kelly.