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Sead Dado Salkovic To prevent consequences similar to those in the European countries regarding current debt crisis, the Montenegrin government plans to implement a number of economic measures by the end of the year, which will mostly concern public sector spending.

Elena Kostovska In April, FYR Macedonia signed a treaty for the avoidance of double taxation with its newest neighboring state, Kosovo. The two countries have recently made steps toward boosting the cross-border economic cooperation, with multiple joint projects, activities as well as meetings between the chambers of commerce. In 2010, the total exchange between the two countries increased by 41% and FYR Macedonia's exports to Kosovo are estimated at a significant amount of $300 million.

Wiwin Siswanti The Directorate General of Taxes (DGT) of Indonesia has issued two regulations regarding the settlement of transfer pricing disputes, namely, PER-69/PJ/2010 regarding advance pricing agreement (APA) and PER-48/PJ/2010 regarding mutual agreement procedure (MAP).

Rajendra Nayak Ganesh Pai The Authority for Advance Rulings (AAR) in the case of Columbia Sportswear Company [2011-TII-21-ARA-INTL], adjudicated on the taxability of procurement activity undertaken by a non-resident company through its liaison office (LO) in India. The taxpayer, a US company (US Co) engaged in worldwide wholesaling and retailing of outdoor apparel, set up a LO in India to act as a liaison for the purchase of the goods in India. The LO also assisted the US Co in procuring goods from Egypt and Bangladesh. The Indian Tax Law (ITL) provides for an exemption from income attributable to business operations in India, where the activity of a nonresident is limited to purchase of goods for the purpose of export (purchase exclusion). Also, under most tax treaties, a place of business maintained solely for the purpose of purchasing goods, or activities that are preparatory or auxiliary in nature, does not create a taxable presence/permanent establishment (PE) for the non-resident enterprise. The issue before the AAR was to determine whether the LO of US Co would come within the purview of the purchase exclusion under the ITL or not create a PE under the applicable India-US tax treaty.

Janne Juusela The Finnish Central Tax Board (CTB) has given a preliminary ruling (KVL 34/2011) regarding taxation in connection with transfers of investments in life insurance saving agreement and capitalisation agreement where the taxpayer has the right to decide on which assets the policy funds are invested in.

Bob van der Made A single European market in the area of taxation still does not exist. In practice, this means that multinational corporations doing business in the EU need to navigate their way through (up to) 27 different national tax administrations and administrative requirements, and widely differing national interpretations of EU tax law, directives and regulations. But Europe's direct tax policy landscape is changing fast and in a fundamental way as a result of the growing economic and political pressures to manage and find a sustainable solution out of the financial and economic crisis. Highly controversial EU policy options which were previously unthinkable are now tabled. Marked examples are the European Commission's proposals for a common consolidated corporate tax base (CCCTB) and a financial transaction tax (FTT), as well as the relatively quickly adopted EU "six-pack" proposals on financial sector regulation.

Giannos Ioannou Georgia Papa The first package of austerity measures was voted by the House of Representatives on August 26 2011. The measures intend to assist Cyprus in reducing expenditure while increasing revenue and at the same time maintaining Cyprus's reputation as a stable and competitive financial centre. The changes entail amendments to various laws, including amendments to the immovable property tax whereas a second and most likely a third package of further financial changes is expected in subsequent months.

Simeon Grigorov Anna Zafirova The effects of the economic recession felt in a particularly strong way in certain EU member states have resulted in migration of many foreign companies to Bulgaria. Being one of the countries in the EU with the lowest (10%) corporate tax rate, Bulgaria offers stable economic environment, as well as simple and cost-effective procedure for accommodating businessmen searching for tax optimisation of their investments.

Nélio Weiss Philippe Jeffrey As widely known, Brazil's transfer pricing rules do not adopt the internationally accepted arm's-length standard. For instance, for the purposes of applying the Brazilian equivalent to the resale price method (PRL) in transactions involving import of goods between related parties abroad, regulations provide the use of statutory fixed margins to derive a benchmark ceiling price. In these instances, actual transfer pricing practiced by the local tested party must be lower than that derived benchmark price, otherwise tax authorities will impose a transfer pricing adjustment.

Samir Haouari Following the implementation of the so-called VAT package, the rules on the place of supply of services have significantly changed. As a general rule, in a B2B context, services are now taxable for VAT where the recipient is established. However, services for the admission to cultural, artistic, sporting, scientific, educational, entertainment, or similar events, remain taxable for VAT where the event physically takes place.