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Jim Fuller

Hans Rudolf Habermacher

"To access overseas cash, even for domestic investments, there is a significant incentive for tax headquarters to migrate abroad. The ideal solution is for Congress to rewrite the corporate tax code… So far, nothing has happened. As a consequence, US companies are finding alternative approaches such as tax inversions."

Arun Jaitley, Indian finance minister, wants to end continuing uncertainty surrounding the implementation of the goods and services tax (GST) by introducing the regime by the end of this year.

Elena Kostovska The corporate income tax system in FYR Macedonia – since its groundbreaking revamping in 2011 – has been mostly concerned with the unrecognised (non-deductible) expenses of a company for the purposes of determining its tax base, as opposed to the actual profit of a company. However, within the past three years of the validity of this novel corporate income tax regime, and due to the resulting shrinking of the tax base of companies, the government and tax authorities are finding themselves in a constant loop of amendments aimed at widening the tax base by effectively introducing new categories in the so-called unrecognised expenses list.

David Cuellar

China’s State Administration of Taxation (SAT) published its discussion draft on ‘Administrative Measures on the General Anti-Avoidance Rule (GAAR)’ this month, which outlines key principles and procedural guidelines for its implementation, but there is still more work to be done.

Chris Harker New Zealand's Inland Revenue has recently finalised a series of public rulings (BR Pub 14/01 to 14/05) regarding the ability of a New Zealand resident partner of an Australian limited partnership (ALP) to claim foreign tax credits for tax paid by the limited partnership. The rulings apply from the 2013/2014 income year. The rulings concern ALPs that are treated as companies for Australian tax purposes, but are fiscally transparent for New Zealand tax purposes. The rulings will, however, be of general interest to persons that are considering New Zealand inbound or outbound investment involving a hybrid entity (that is, an entity that has transparent tax treatment in one jurisdiction, but that is taxed as an entity in its own right in another).

John Kwak

Privacy concerns still hamper the re-proposed rule What a messy few months Argentinean football star, Lionel Messi, has had with the Spanish tax authorities. We are used to seeing the diminutive star running rings around his opponents on the football field, but recently the question has arisen as to whether Messi has been trying to run rings around the taxman, too. Thankfully for him, and the rest of his countrymen, his performance on the pitch has not suffered, and now neither will his bank balance, after the case against him in relation to charges of tax fraud was dropped by prosecutors. Leo can now let out a sigh of relief and focus all of his attention on the 2014 FIFA World Cup in Brazil safe in the knowledge that he will not have to swap his blue and white jersey for an orange jumpsuit.