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Andrey Grachev Anton Borisichev The Russian State Duma has accepted a legislative proposal (Draft Law No 962487-6) related to new VAT rules for electronic services (e-services). In all likelihood the draft law will be amended several times before its final adoption and enforcement, but content analysis shows its main purpose is to get foreign companies registered for VAT in Russia and remitting tax on services that are electronically supplied.

Many of our readers will have been eagerly awaiting the sound of ITR's February issue hitting their hallway floor after we moved our landmark Global Tax 50 feature to this edition to accommodate last month's BEPS Special.

David Forst, Jim Fuller, Adam Halpern and Andrew Kim of Fenwick & West provide an update on recent US Treasury and IRS action which is impacting outbound transfers to foreign corporations. The impact of the Altera case, as well as recent anti-inversion action, is also analysed.

Mexico is one of the few countries with a special exemption regime for foreign pension funds investing in the country. This exemption was incorporated into the tax system as a general withholding exemption for such funds when obtaining any type of Mexican source income through a presidential decree published on March 25 1992, and then into the Income Tax Law in July of that year. Raul Morales Medrano of Chevez, Ruiz, Zamarripa y Cía, outlines the latest changes impacting pension funds in Mexico.

Dorina Asllani Ndreka The government of Albania has announced a new tax reform which includes the removal of the obligation to pay the simplified income tax for small businesses with annual turnover up to €36,000 (or 5 million ALL).

Andrés Edelstein Ignacio Rodríguez On December 17 2015 the Argentine Central Bank (BCRA) issued Communication A 5850 by which important amendments where introduced to the Exchange Currency Market (MULC) regulations related to the payment of imports of goods and services as well as to the requirements for the formation of foreign assets by Argentine residents, and to the regulations related to financial debts with non-residents.

Melissa Lim As a result of and consistent with increased international cooperation via G20/OECD actions in 2015, Australia's 2016 tax landscape will be dominated by a focus on combating perceived or actual multinational tax avoidance. The biggest impact will be on 'significant global entities', that is, those with an annual global income of A$1 billion or more.

Christiana Nicolaou As the need for tax efficient structures has been magnified with the recent global economic downturn and the increased scrutiny from tax authorities worldwide, companies need to carefully select the jurisdiction they use for implementing such structures, while also being very careful about substance, so as to be able to mitigate any risks and taxes.

Tim Stewart The Court of Appeal has ruled in favour of the taxpayer in Commissioner of Inland Revenue v Diamond, concluding that the taxpayer was not resident in New Zealand for tax purposes. The Court dismissed Inland Revenue's appeal against the High Court Judge's decision, and rejected Inland Revenue's argument that Diamond's New Zealand residential investment property was a "permanent place of abode".

Rafael Calvo Juan Salvador Pastoriza On December 17, the European General Court (EGC – a constituent court of the ECJ) handed down a judgment on joined cases T-515/13, Spain / Commission, and T-719/13, Lico Leasing, SA and Pequeños y Medianos Astilleros Sociedad de Reconversión, SA / Commission. That judgment overturned the Commission's decision on a proceeding finding that the Spanish tax lease system (STLS) constituted illegal state aid, because the EGC considered that the measures composing that system do not constitute a selective advantage.