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Igor Vujasinovic On June 16 2015, in accordance with articles 7 and 8 of the Law on Indirect Taxation System in BIH (Official Gazette No. 44/03, 52/04, 34/07, 4/08, 49/09 and 32/13) in conjunction with article 25 of the Law on the Indirect Taxation Authority (Official Gazette 89/05) the Director of Indirect Taxation, with the approval of the Boards of Directors, issued a decision (the Decision) on the threshold for large VAT taxpayers. The Decision determines the period and prescribes the conditions which serve as a standard for determining which indirect taxpayers will have the status of 'large indirect taxpayers'.

Peter Dachs South Africa's new double tax agreement (DTA) with Mauritius was published in the Government Gazette of June 17 2015. In terms of article 28 of the new DTA, the provisions thereof shall only be effective in both countries from January 1 2016. The main changes introduced by the new DTA relate to dual residence for persons other than individuals, withholding taxes (dividends, interest and royalties) and capital gains.

Alvaro Pereira

Luis Manuel Viñuales So far 2015 has been an exciting year for Spanish tax practitioners thanks to the major reforms we have seen in the area of income taxes. Although the focus has been on a brand new Corporate Income Tax Law and on the relevant changes to the Personal Income Tax Law, we should not overlook the amendments made to the Non-Resident Income Tax Law (NRIT Law) and, in particular, to the tax treatment of capital gains obtained by non-residents on the transfer of shares of Spanish companies. The domestic NRIT Law in force until December 31 2014 stated that capital gains obtained by EU residents on the transfer of shares of Spanish entities could only be taxed in Spain if a) the underlying assets were mainly real estate located in Spain or if b) the seller owned at least 25% of the company during the 12 months before the transaction. Capital gains obtained by non-EU residents on the sale of Spanish non-listed entities were always taxed in Spain unless a tax treaty provided otherwise.

Petar Varbanov On July 8 2015, the Bulgarian Parliament ratified the convention for the avoidance of double taxation concluded with the Kingdom of Norway. The convention will apply to persons who are residents of one or both of the contracting states and to any substantially similar taxes that are imposed after the date of signature of the convention in addition to, or in place of, the existing taxes. The existing taxes to which the convention will apply are taxes on income, municipal tax on income, tax relating to submarine petroleum income, pipeline transport of petroleum, national tax on remuneration to non-resident artistes, corporate income tax and patent tax. Income derived by a resident of a contracting state from immovable property (including income from agriculture or forestry) situated in the other contracting state may be taxed in that other state. Also, business profits of an enterprise of a contracting state will be taxable only in that state unless the enterprise carries on business in the other contracting state through a permanent establishment (PE) situated therein. Profits of an enterprise of a contracting state from the operation of ships, aircraft, and railway or road transport vehicles in international transport shall be taxable only in that state.

Jeffrey Shafer

Hans Rudolf Habermacher

Devrim Askin Turkish Revenue Administration (TRA) recently published draft guidelines on advance pricing agreements (APAs) with the aim of informing corporate taxpayers planning to apply for an APA. In this context, the draft guidelines provide information regarding: definition, scope and duration of APA; APA process which consists of five steps (pre-filing, formal application, preliminary evaluation, analysis, and unconditional/conditional acceptance or rejection of the application); preparation of annual APA report for monitoring the implementation of the signed APA; and revision, renewal and cancellation of an existing APA. In fact, the draft guidelines reiterate the explanations already made in the existing transfer pricing legislation, particularly the provisions contained in the Transfer Pricing General Communiqué No.1. However, more specific information is requested by TRA from taxpayers in their APA application than those listed under section 7.2 of the above-mentioned General Communiqué No.1, including:

Khoonming Ho

Jim Fuller