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Petar Varbanov Bulgaria is an attractive location for a variety of reasons, including the landscape of political and business stability and the country's membership of the EU, NATO and WTO. The stability of the currency is supported by the currency board, pegging the Bulgarian lev to the euro at the level of 1.96. Bulgaria has one of the lowest government debts in the European Union (18.9% of GDP) and one of the lowest budget deficits (-1.5%) as of 2013. Bulgaria also benefits from a strategic location and provides direct access to: the EU market – zero tariff market with population of 500 million; the Commonwealth of Independent States (CIS) – a market which is still not very well penetrated but which has great potential; Turkey – zero tariff market with a population approaching 80 million; Middle East – a market with high purchasing power; and the North African market. Due to all the above stated positives and also low tax rates, Bulgaria has become a very friendly environment for foreign investors looking to do business in Bulgaria.

Loreto Pelegrí

Ed Kroft, QC

Barcelona’s Neymar is known for his evasive dribbling on the pitch

Alexander Linn

Khoonming Ho

Ayesha Lau

Samantha Schmitz-Merle The Luxembourg Government recently presented to parliament a draft law ratifying four double tax treaties (DTTs) concluded by Luxembourg with Andorra, Croatia, Estonia and Singapore and six protocols to existing DTTs concluded with the UAE, France, Ireland, Lithuania, Mauritius and Tunisia. While most of the protocols only aim to bring the exchange of information provisions of existing DTTs in line with OECD standards, the protocol to the Luxembourg-France DTT, the ratification process of which has been closely followed, amends the rules dealing with the taxation of capital gains on the sale of shares in property companies. The new DTTs generally follow the OECD Model Tax Convention. We present the main provisions. As far as residence is concerned, according to the DTTs concluded with Andorra, Croatia and Singapore, companies are, in case of conflict, considered resident in the country in which their place of effective management is located, in line with the current version of the OECD Model Tax Convention. However, under the DTT with Estonia, conflicts of company residence have to be settled by the contracting states by mutual agreement, meaning that the two countries will have to agree on the country in which the company will be considered as resident for DTT purposes. Even though solving conflicts of tax residence by the mutual agreement of the competent authorities is in accordance with the latest draft recommendations under the OECD's work to counter base erosion and profit shifting (BEPS), leaving it to the contracting states to solve these issues is an approach which runs the risk of being impractical and which means a lot of legal uncertainty for taxpayers.

Andrea Pavlicevic Since becoming independent in 2006, the government of Montenegro has recognised the need to eliminate obstacles and reform the business environment to open the economy to foreign investors and bring it closer to the European Union. One important recent step in this regard is related to the seventh art. The government plans to adopt the Law on Cinematography, which provides the return of part of the funds spent by foreign producers filming in Montenegro.

With the US Foreign Account Tax Compliance Act (FATCA) reporting deadlines approaching, foreign financial institutions (FFIs) should ensure they understand the impact of FATCA in their organisation and the compliance requirements they are subject to under the intergovernmental agreement (IGA), signed or agreed in substance, between the US and several countries in the GCC including: the Kingdom of Saudi Arabia (KSA), United Arab Emirates, Kuwait, Qatar, and Bahrain.