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Sead Dado Salkovic Over the past few years construction bussinesses have been extraordinarily dynamic and intensive in Montenegro. Even though the investment boom has slowed thanks to the current economic recession, a new wave of infrastructure projects are still waiting to be implemented. Nevertheless, construction of housing and tourist complex concessions remain a main government priority, which they hope will increase investments into the tourism industry.

Elena Kostovska Withholding tax is tax paid on corporate income that non-resident entities realise in FYR Macedonia. The payment of withholding tax is the liability of domestic companies and individuals as well as non-resident companies and individuals with a permanent establishment in FYR Macedonia. These entities and individuals are obliged to withhold the tax when paying the non-resident entity. Companies with a permanent establishment in the republic are taxed on their income through the taxation of the local permanent establishment which is subject to profit tax.

Keith O’Donnell Samantha Nonnenkamp The law of December 17 2010 introduces some tax measures, which aim to restore budgetary balance. Another law of the same date implements the EU's UCITS (Undertakings for Collective Investment in Transferable Securities) IV Directive into Luxembourg law and introduces several positive tax measures for investment funds and management companies.

Rajendra Nayak Ganesh Pai The Delhi Tribunal in the case of eFunds Corporation and eFunds Solutions [2010-TII-165-ITAT-DEL-INTL], adjudicated on the issue of whether their Indian subsidiary performing certain outsourcing functions, results in a permanent establishment (PE) for the taxpayers. The taxpayers are residents of the US and are service providers to financial institutions, electronic fund transfer networks, government agencies, etc, under the following business segments: ATM management services, electronic payment services, decision support and risk management services and professional services. In India, the subsidiary carried on outsourced services for the taxpayers by way of call centre services, financial shared services, data entry and software development services. The issue before the tribunal was whether the activities of the subsidiary created a PE for the taxpayers in India under the India-US tax treaty.

Virginie Louvel Severine Defert The French provision of article 119 bis 2 of the French tax code that imposes a withholding tax (WHT) on outbound dividends while not subjecting French-resident investors to the same is a prohibited restriction on the free movement of capital in the EU which cannot be justified. This is based on the arguments in March 2010, when the European Commission asked France to amend its tax regime.

On December 14 2010 the Cyprus Parliament introduced several amendments to Cypriot tax legislation, which were published in the Official Gazette on December 31 2010 and are outlined below.

Simeon Grigorov At the end of 2010, the Bulgarian Parliament adopted a number of changes in the Corporate Income Tax Act (CITA), some of which will have a significant beneficial effect on cross-border transactions.

Dirk Van Stappen The Belgian tax administration has issued a circular letter (AFZ/AAF nr 13/2010 of 30 November 2010, nr Ci/RH. 421/607.890, AAF/AGFisc 64/2010) commenting on the reporting obligation for payments to tax havens.

Ian Farmer Following the highly publicised actions taken by the Australian Taxation Office (ATO) against a foreign private equity (PE) investor in the wake of the 2009 listing of an Australian department store business (Myer), the ATO issued two final tax determinations (TDs) and two new draft TDs in December 2010.

Robert Waterson of Dorsey & Whitney explains why developments in VAT compound interest litigation have raised concerns for both taxpayers and HMRC over VAT claims.