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Aleksandra Rafailovic After Serbia's double taxation avoidance agreements with Georgia, Canada, Tunisia and Vietnam became effective on January 1 2014, the list of 54 treaty states will soon be extended by Armenia, the agreement with which was ratified in July. The treaty on the avoidance of double taxation between the Government of the Republic of Serbia and the Government of the Republic of Armenia was signed in Yerevan on March 10 2014, while the law on ratification, and the text of the treaty, were published in the Official Gazette of Republic of Serbia no. 7/14 of July 3 2014, and will enter into force in the near future, once ratified by the Republic of Armenia.

Christos Kourouniotis Transfer pricing provisions have existed in the Greek tax legislation since as early as 1958, but it was not until 2008 that the burden of proof was shifted to the taxpayer with the introduction of transfer pricing (TP) documentation requirements. Thus, after a 50-year period during which the taxpayer was not required (unless challenged by the tax auditors) to demonstrate the arm's-length nature of its intragroup transactions, we have experienced a six-year period during which the Greek taxpayer has been required to prepare documentation on an annual basis and under three different sets of documentation, whereas quite recently a fourth set of documentation requirements was introduced.

Ayesha Lau

Bob van der Made The Informal ECOFIN Council meeting on September 13 2014 in Milan included a behind-closed-doors political discussion among the EU-28 finance ministers on the way forward with the EU financial transaction tax (FTT) under enhanced cooperation (no minutes or conclusions of these informal council meetings are published). It is understood that although no substantial progress has been made or communicated after the informal ECOFIN, it seems that the participating EU-11 member states in the enhanced cooperation procedure (EU-11; Austria, Belgium, Estonia, France, Germany, Greece, Italy, Portugal, Slovakia, Slovenia and Spain) are now closer to a compromise agreement than they have been. The project now seems to go in the direction of a UK-style stamp duty but with revenue sharing among the participating member states to keep the smaller EU-11 on board.

Rajendra Nayak

Giuliano Foglia

Elena Kostovska With the latest amendments to the Law on VAT published in the Official Gazette on August 5 2014 and effective as of August 6 2014, the reduced VAT rate (5%) is now applicable to new categories of products that were previously subject to the regular VAT rate of 18%. These new categories include:

Emilie Fister Luxembourg continues to expand its double tax treaty (DTT) network with the ratification of five new DTTs (with Saudi Arabia, Jersey, Guernsey, the Isle of Man and the Czech Republic), two protocols to existing DTTs (with Denmark and Slovenia) and a double taxation agreement entered into with Taiwan. These new DTTs share some common features with the alignment of these DTTs and protocols with the OECD standards on exchange of information and the granting of treaty benefits to collective investment vehicles (CIVs). We present the main features. The protocol to the new Saudi Arabia-Luxembourg DTT provides that CIVs are considered as residents and beneficial owners of the income they earn. No distinction is made between CIVs in corporate form (SICAVs/SICAFs) and in contractual form (FCPs).

Tim Stewart Expatriates with residential investment properties in New Zealand can breathe easier after the High Court allowed the taxpayer's appeal in Diamond v Commissioner of Inland Revenue. The case concerned whether a residential investment property in New Zealand that Diamond had owned but never lived in could be his "permanent place of abode" such that Diamond was a New Zealand tax resident and, therefore, liable to New Zealand tax on his worldwide income. New Zealand has two main tests to determine if an individual is tax resident. A day-count test and the "permanent place of abode" test. It is only necessary to satisfy one of these tests. Diamond was not resident under the day-count test as he was absent from New Zealand for the required period of time during the relevant tax years.

Peter Dachs South Africa taxes a resident, as defined in the Income Tax Act, on its worldwide income. A South African resident is defined in section 1 of the Income Tax Act as a person (other than a natural person) which is incorporated, established or formed in the Republic or which has its place of effective management in the Republic, but does not include any person who is deemed to be exclusively a resident of another country for purposes of the application of any double taxation agreement entered into by South Africa.