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Gary Gowrea Mauritius continues to accelerate its position as a major financial hub by entering into new investment promotion and protection agreements as well as continuously expanding its double taxation avoidance agreement (DTAA) network. With a fast expanding tax treaty network, the scope for tax planning opportunities is thereby enhanced, thus improving the image of the Mauritius as a jurisdiction of choice for structuring investments.

Elena Kostovska For the second time in six months, the FYR Macedonian VAT legislation has been revised. Whereas the last revisions (applicable from 2010) touched on VAT registration deadlines, submissions statements, and changes to the transfer of assets and real estate sales, amendments adopted in late July 2010 mostly concern VAT registration threshold, penalties and new reports submitted along with the tax returns.

Rosanne Bonnici On October 25 ,Tonio Fenech, the Minister of Finance, the Economy and Investment, delivered the 2011 Budget and announced a number of fiscal measures aimed at incentivising internationalisation and promoting investment and business.

Gary Thomas The Japanese government is seriously considering the adoption of the best method rule as the basic principle upon which to determine the transfer pricing method to be applied by a taxpayer.

Loïc Le Claire Richard Juan The 2011 French Finance Bill preserves the attractiveness of the French IP/IT incentives. This includes the R&D tax credit and the reduced taxation of patents. Adjustments to the existing regimes, in force as from January 1 2011 (except the immediate refund, since 2010), include the following:

Janne Juusela The Finnish Supreme Administrative Court has issued a ruling which states that a transfer of employees does not necessarily hinder the applicability of a granted special permit relating to the right to deduct a company's tax losses despite a change of ownership.

Slobodan Mihajlovic Zoe Kokoni The income tax treaty with Denmark, concluded October 11 2010, will enter into force following the ratification by both countries. Once in force, it will replace the previous treaty from 1981.

Alke Fiebig On October 29 2010, the Bundestag passed the Annual Tax Bill 2010 (for 2011) and forwarded it to the Bundesrat for final approval. One of the main features is a change to the CFC rules to counter a perceived abuse. The principle behind the CFC rules is to attribute passive income to the German parent if retained by a foreign subsidiary after effective taxation of less than 25%.

Jean Marc Gagnon Emmanuel Sala In a decision rendered from the bench, the Federal Court of Appeal of Canada (FCA) has dismissed the Crown's appeal in the Collins & Aikman case. In this case, the taxpayer had undertaken a reorganisation resulting in a recognition of cross-border paid-up capital which was subsequently distributed Canadian tax-free to the non-resident shareholder.

Simeon Grigorov Considering a company's activity from a tax perspective, one of the most essential issues is the scope of application of any allowable deductions. From a Bulgarian prospective, expenses incurred wholly and exclusively for the production of income are treated as deductible expenditure. It is widely used by companies to include the interest payments as part of their expenditures. The question is, however, whether or not, or how much of such interest payments are deductible or not.