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Philippe Jeffrey

Donka Pechilkova On January 1 2014, Bulgaria took one more step forward to the synchronisation of the local Bulgarian legislation with the European one by passing changes in the Law on Value Added Tax by applying a special regime of cash reporting for Bulgarian entities. This kind of reporting is well known in more than twenty EU member states and they have proved their good results. The main principle underlying this regime is the VAT to be payable in the tax period when the company received payment, fully or partially, from its client but not when the related invoice is issued. Respectively companies, registered under this regime will accrue and deduct VAT of the preceding deals after payment to the supplier is executed. Once payment is executed a protocol for payment should be issued and based on this protocol the relevant amount will be included into the VAT statement for the related tax period. It is important to note the regime is applicable only for deals that have place of performance in the territory of Bulgaria, and is not applicable for import of goods, inter-community sales and deliveries; zero rated deals; deals between related parties and sales to non-registered under VAT regime entities. The regime does not have a mandatory character and Bulgarian companies can choose to register voluntary under this regime.

Soraya M Jamal

Sandra Benedetto

Khoonming Ho

Zoe Kokoni Article 51A of the Immovable Property Legislation (Tenure, Registration and Valuation) (Amendment) Law, 1960 (N. A3/1960) has been amended to include Section 3, according to which the director of Department of Land and Surveys, upon the request of a credit institution, shall provide immediately any information related to immovable property, registered under the name of a physical or legal person. However, the credit institution must first acquire a license from the Department of Land and Survey to be able to request information from the Land Registry. The credit institution must state in its application the reason(s) under which they have the right to receive this information and that renders them an interested party. At the same time it must inform in writing the relevant person, for whom the information is requested, stating also the reasons.

Bob van der Made The Lithuanian EU Presidency presented its end-of-term six-monthly progress report on the EU Code of Conduct Group (Business Taxation) to the ECOFIN Council. With regard to the code group, the ECOFIN Council (the EU-28 finance ministers) of December 10 2013 subsequently:

The European Commission is optimistic the financial transaction tax (FTT) could be ratified as early as May.

Petra Peitz-Ziemann

Dionisios Stathis On July 26 2013, new Greek Tax Procedure Code (l. 4174/2013) was enacted by the Greek Parliament, which introduced for the first time the concept of general anti-avoidance rule (GAAR). In particular, according to the newly established rule, effective as of January 1 2014, the tax administration has the right to ignore any artificial arrangement or series of artificial arrangements giving rise to tax avoidance or tax benefits in general. The new rule provides for a definition, scope and brief description of the terms "arrangement", "series of arrangements" and "artificial". As regards scope, it applies to cases where the legal treatment of a sole arrangement differs from the legal treatment of a series of arrangements taken together, where no sound business reasons exist for the effecting of the arrangement (or series of arrangements), where the various arrangements taken as a whole contradict to and cancel each other and where the tax benefit(s) obtained do not reflect the business risks undertaken by the contracting parties. It is interesting to note that, contrary to other jurisdictions, Greece did not have so far any legal tradition in respect of substance over form or similar principles or doctrines emanating either from case law or from legal practice in general. Perhaps the only relevant concept in Greek legal theory was that of sham or fictitious transactions found predominantly in Greek civil law. Traditionally the Greek tax administration used to apply in the course of both domestic and treaty law the opposite general principle of form over substance which was based on the widely accepted notion that the tax rules must be interpreted narrowly by the tax administration.