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Jim Fuller

Sean Foley

A monthly commentary on the notable facts, figures and goings-on in the tax world.

Giuliano Foglia

Elena Kostovska Despite rumors about changes in the taxation rates in the country, the FYR Macedonian government approved the Budget for 2014 without any changes in the taxation regime. The Budget for 2014 was published in the Official Gazette No.183 of December 23 2013. According to the Budget, government incomes are estimated at around MKD158 billion ($3.5 billion), whereas expenses are expected to reach MKD176 billion. The budgetary deficit projected at 3.5% will be financed from domestic and foreign sources while GDP growth is expected to be 3.2%. The government estimates that the budgetary inflows from taxes and contributions will amount to about 75% of all inflows, whereas penalties are expected to bring in additional 9% of the projected incomes.

The increased diversification of the digitised economy presents a major challenge for BEPS initiatives. Lack of a permanent establishment (PE) had led to debate over where tax should be applied, even where a digital entity is not practising a tax avoidance strategy. The prospect of amended tax legislation to address this has raised concerns over the increased risk of double taxation, and a regulatory burden on multinationals.

There is no doubt that companies are becoming more transparent in reporting and disclosing their tax affairs. But they are still not going far enough, according to tax justice campaigners.

Tim Stewart Vinelight Nominees Limited v CIR is the New Zealand Court of Appeal's latest decision on the general anti-avoidance rule (GAAR) and the tax resident test for companies. The decision also addresses the time limitation on Inland Revenue's ability to re-assess taxpayers, and a taxpayer's ability to raise new arguments in the course of court proceedings. The case arises from a restructure of a family's investments in 1998, following advice from EY. The family carried on business in New Zealand through Vinelight Investments Limited (VIL), a New Zealand tax resident company. The family also owned Weyand Investments Limited (Weyand), a Hong Kong incorporated company.

Alcoa’s operations in Europe, Middle East and Africa run from Norway in the north of the region to South Africa in the south. It is a wide area of responsibility for the EMEA tax department of the global engineering and manufacturing company, which makes it crucial that when it uses external advisers, it finds the right ones to help it contribute to the company’s objectives.

The British Bankers Association (BBA) has called on Chancellor of the Exchequer George Osborne to end the bank levy. His 2014 Budget is less than a month away.