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International Tax Review analyses the global M&A trends over the last year and highlights the leading firms in the field.

Rajendra Nayak

Samantha Merle

Donald Vella

David Cuellar

Jelena Zivkovic Budva Municipality, the pearl of Montenegrin tourism, is addopting new incentives for domestic as well as foreign investors for the construction of new hotels and for owners of private accomodations. A year ago, the Budva municipality government adopted an incentive acoording to which investors that are investing in construction of four and five stars hotels are liable to pay €30 ($41) per square metre for local communal fees that is already 10 times less than the fees in previous periods. Now, the municipality intends to reduce the fees to zero.

Anastasia Sagianni The Serbian transfer pricing legislation follows the OECD guidelines and requires that transactions between related parties should be carried out in an arm's length basis. The Serbian tax authorities through the TP Rulebook that was published on July 12 2013 in Official Gazette of RS no. 61/2013, determine the general principles of TP in Serbia. Taxpayers should have the appropriate TP documentation in place to defend their policies in a potential tax investigation. Companies and group of companies with related party transactions are affected by transfer pricing rules.

Jay Shim On December 30 2013, the Strategy and Finance Committee of the National Assembly reviewed and voted on the amended proposals and legislative Bills submitted by the government. Through a plenary session, the proposed legislation and tax laws adopted by the Strategy and Finance Committee was finally approved by the Legislation and Judiciary Committee of the National Assembly on January 1 2014. Below are some of the notable changes in the Korean tax law that may be relevant to foreign companies doing business in Korea and foreign-owned Korean companies. Not surprisingly and to the disappointment of foreign investors, the recent trend to scale back the various tax benefits and incentives created during the Korean IMF crisis to encourage foreign investments appears to continue.

Peter Dachs The issue arises as to whether a foreign company is required to submit an income tax return. In this regard section 67(1) of the Income Tax Act provides that every person who at any time becomes liable for any normal tax or who becomes liable to submit any return contemplated in section 66 must apply to the Commissioner to be registered as a taxpayer.

Alvaro de la Cueva Under Spanish tax law, corporate income taxpayers that realise a gain on the sale of a holding of more than 5% in a resident entity in Spain are entitled, provided the holding has been owned for more than one year, to take a corporate income tax credit equal to the portion of the gain that relates to the reserves of the investee that have already been taxed at the investee. However this mechanism, which aims to eliminate the double taxation that would arise if the income was first taxed at the investee and then on the occasion of the gain, is not reflected in the non-residents income tax.