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Nemanja Paskulov The news release from the Canadian Ministry of International Trade highlighted the importance of FIPAs for ensuring the fair treatment of investors and the creation of a more predictable and transparent business environment through reciprocal, legally binding provisions, by setting out clear rules governing investment relations, including in areas of dispute resolution and protection against discriminatory and arbitrary practices, giving businesses greater confidence to invest. Furthermore, the Ministry announced that Serbia is an important commercial partner in southeastern Europe, identifying many areas of potential growth for Canadian investment in Serbia, from the extractive and resource industries and the energy and power generation, to transportation infrastructure and agri-food sectors. Canada-Serbia relations have been strengthened in recent years by a number of bilateral agreements, including a double taxation agreement and social security and air transport agreements.

Gonzalo Gallardo Dividend income and capital gains obtained on transfers of shareholdings in other companies, whether resident in Spain or not, have been exempt from Spanish corporate income tax since January 1 2015 (whereas the previous participation exemption regime covered certain capital gains and dividends only from foreign sources). For this exemption to be applicable, the shareholding must be at least 5% (or its acquisition cost must be more than €20 million ($23 million)) and it must have been owned for an uninterrupted period of at least one year (the 'minimum participation requirement'). If the investee is an entity not resident in Spain, it is also required to have been subject abroad to a tax identical or similar to the Spanish corporate income tax, at a nominal rate of at least 10% ('the minimum taxation requirement'), this latter requirement being presumed met if it is resident in a country with which Spain has signed a tax treaty containing an information exchange clause.

Nokia India’s latest dispute with the Indian tax authorities kicked off on Tuesday [May 26 2015] in the Delhi High Court.

Jim Fuller

Umurcan Gago

"From a political perspective, aggressive tax planning and the overall lack of transparency across Europe have a corrosive effect on the principle of 'no taxation without consent'. Democratic accountability is also at risk when large corporations are in a position to make member states compete to house their headquarters or operations: the prerogative to set the level of taxation is no longer exercised by citizens and their representatives, but by multinational corporations."

Plans for sweeping changes to the VAT system, which would cut the rate businesses pay from 23% to 15%, have been rejected by Greece’s creditors.

The latest international updates from our correspondents around the world.

Though China has had an advance pricing agreement (APA) programme for nearly a decade, some businesses report that obtaining APAs in China is challenging due to a lack of manpower at the State Administration of Taxation’s (SAT) transfer pricing team.

In its judgment dated May 21 2015 (Wagner-Raith) the European Court of Justice (ECJ) confirmed that the German lump-sum taxation according to section 18 paragraph 3 of the German Foreign Investment Act (GFIA), as effective until the end of 2003, is within the scope of the standstill clause of article 57, EC Treaty.