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CEE Tax Notes Working Cross-Border*

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CEE Tax Notes Working Cross-Border* CEE Tax Notes Working cross-border* Issue No. 8/3 Second Electronic Update Country News • Albania • Armenia • Azerbaijan • Bosnia and Herzegovina • Bulgaria • Croatia • Czech Republic • Estonia • Georgia • Hungary • Kazakhstan • Latvia • Lithuania • Macedonia • Moldova • Montenegro • Poland • Romania • Russia • Serbia • Slovakia • Slovenia • Ukraine • Uzbekistan *connectedthinking PricewaterhouseCoopers Tax Contacts for CEE: CEE Tax and Legal Services Leader Bosnia and Herzegovina (Sarajevo) Russia (Moscow) Janos Kelemen Steven Snaith Tel: + 386 1 5836 058 Tel: + 7 495 232 5524 Fax: + 386 1 5836 098 Fax: + 7 495 967 6001 Email: [email protected] Email: [email protected] Bulgaria (Sofia) CEE Tax and Legal Services Markets Partner Irina Tsvetkova Tel: + 359 2 9355 126 Ukraine (Kiev) Fax: + 359 2 9803 228 Ron Barden Email: [email protected] Tel: + 380 44 490 6777 Fax: + 380 44 484 0966 Croatia (Zagreb) Email: [email protected] Janos Kelemen Tel: + 385 1 6328 880 CEE Tax Notes Editor Fax: + 385 1 6111 556 Hungary (Budapest) Email: [email protected] Tibor Torok Tel: + 36 1 461 9371 Czech Republic (Prague) Fax: + 36 1 461 9559 Paul Stewart Email: [email protected] Tel: + 420 2 5115 2711 Fax: + 420 2 5115 7711 Albania (Tirana) Email: [email protected] C/O Rene Bijvoet (Serbia) Estonia (Tallinn) Loreta Peci C/O Mike Ahern (Poland) Tel: + 355 4 242 254 Villi To˜ntson Fax: + 355 4 241 639 Tel: + 372 614 1970 Email: [email protected] Fax: + 372 614 1980 Armenia (Yerevan) Email: [email protected] C/O Courtney Fowler (Kazakhstan) Georgia (Tbilisi) Paul Cooper C/O Courtney Fowler (Kazakhstan) Tel: + 374 10 592 150 Matthew Tallarovic Fax: + 374 10 501 341 Tel: + 995 32 508 050 Email: [email protected] Fax: + 995 32 508 060 Email: [email protected] Azerbaijan (Baku) C/O Courtney Fowler (Kazakhstan) Hungary (Budapest) Movlan Pashayev Russell Lambert Tel: + 994 12 497 7405 Tel: + 36 1 461 9223 Fax: + 994 12 497 7411 Fax: + 36 1 461 9115 Email: [email protected] Email: [email protected] PricewaterhouseCoopers CEE Tax Notes 2008/3 PricewaterhouseCoopers Tax Contacts for CEE: Kazakhstan (Almaty) Russia (Moscow) Courtney Fowler Bill Henry Tel: + 7 727 298 0615 Tel: + 7 495 967 6023 Fax: + 7 727 298 0252 Fax: + 7 495 967 6001 Email: [email protected] Email: [email protected] Latvia (Riga) Serbia (Belgrade) C/O Mike Ahern (Poland) Rene Bijvoet Zlata Elksnina Tel: + 381 11 3302 100 Tel: + 371 709 4514 Fax: + 381 11 3302 101 Fax: + 371 783 0055 Email: [email protected] Email: [email protected] Slovakia (Bratislava) Lithuania (Vilnius) Todd Bradshaw C/O Mike Ahern (Poland) Kristina Bartuseviciene Tel: + 421 2 5935 0600 Tel: + 370 5 239 2365 Fax: + 421 2 5935 0222 Fax: + 370 5 239 2301 Email: [email protected] Email: [email protected] Slovenia (Ljubljana) Macedonia (Skopje) Janos Kelemen C/O Irina Tsvetkova (Bulgaria) Tel: + 386 1 5836 058 Bob Savic Fax: + 386 1 5836 098 Tel: + 389 71 232 710 Email: [email protected] Fax: + 389 2 311 6525 Email: [email protected] Ukraine (Kiev) Ron Barden Moldova (Chisinau) Tel: + 380 44 490 6777 C/O Mihaela Mitroi (Romania) Fax: + 380 44 484 0966 Andrian Candu Email: [email protected] Tel: + 373 22 238 122 Fax: + 373 22 238 120 Uzbekistan (Tashkent) Email: [email protected] Abdulkhamid Muminov Montenegro (Podgorica) Tel: + 998 71 1206 101 Rene Bijvoet Fax: + 998 71 1206 645 Tel: + 381 11 3302 100 Email: [email protected] Fax: + 381 11 3302 101 German Desk Email: [email protected] Christian Ziegler Poland (Warsaw) Moscow, Russia Iwona Smith Tel: + 7 495 232 5461 Tel: + 48 22 523 4853 Fax: + 7 495 967 6001 Fax: + 48 22 508 4853 Email: [email protected] Email: [email protected] Japanese Business Practice Romania (Bucharest) Belgium (Brussels) Peter de Ruiter Steve Moriyama Tel: + 40 21 202 8670 Tel: + 32 2 710 7432 Fax: + 40 21 202 8600 Fax: + 32 2 710 4299 Email: [email protected] Email: [email protected] PricewaterhouseCoopers CEE Tax Notes 2008/3 Contents PricewaterhouseCoopers Tax Contacts for CEE . Foreword . 1 Albania . 2 Armenia . 3 Azerbaijan . 4 Bosnia and Herzegovina . 6 Bulgaria . 7 Croatia . 8 Czech Republic . 9 Estonia . 11 Georgia . 13 Hungary . 14 Kazakhstan . 16 Latvia . 18 Lithuania . 19 Macedonia . 20 Moldova . 22 Montenegro . 24 Poland . 26 Romania . 27 Russia . 31 Serbia . 33 Slovakia . 35 Slovenia . 36 Ukraine . 38 Uzbekistan . 39 PricewaterhouseCoopers CEE Tax Notes 2008/3 Editor’s foreword As this edition of Tax Notes goes to press, the impact of the global credit crunch continues to reverberate around the world. The effects of these unprecedented events are being felt throughout the CEE region and will be felt for some time to come. If you would like to learn more about managing your business in a downturn please get in touch with your usual PwC contact or [email protected]. Please note that this publication is designed solely for information purposes. Rules and regulations are described in brief and general terms only and should not be regarded as a substitute for professional advice. PricewaterhouseCoopers 1 CEE Tax Notes 2008/3 Albania Tax administration Indirect taxation The tax authorities will classify a taxpayer as a VAT non-operating entity if, for 12 consecutive months: • Services performed in connection with immovable – The taxpayer does not perform any economic activities; property are treated as carried out in the country where – The taxpayer does not submit any tax returns; or the immovable property is located. Therefore, services – The taxpayer declares the termination of its economic such as, but not limited to, the following will be treated activities. as being performed in Albania, and will therefore be subject to VAT: Transfer to the ‘non-operating’ category does not remove a taxpayer’s existing tax liabilities that arose while it was – design; active. This amendment entered into force on 25 June – construction, installation, reconstruction and 2008. maintenance; – supervision, any type of expertise; and Large taxpayers can declare and pay Value Added Tax, – leasing. personal income tax, social insurance and health contributions, and annual profit tax electronically. • When a foreign entity whose usual place of activity is not Albania (i.e. a non-registered foreign entity) provides In October 2008 the government granted a fiscal amnesty services to an Albanian registered entity, the Albanian from which the following cases will benefit: entity should issue a VAT invoice to itself and record it as both a sale and a purchase (reverse-charge – Taxpayers whose debt has been assessed and mechanism). VAT is charged on the consideration for accounted by the tax authorities in a tax inspection, but the service. about which the taxpayer has not been notified within the legal deadline, are exempted from tax and customs • The amendment entered into force on 16 May 2008. liabilities, including penalties and interest. – Taxpayers whose debt is assessed and accounted by the tax authorities in a tax inspection and about which Individual taxation the taxpayer has been notified within the legal deadline, are forgiven penalties and interest as long as the Social security principal is paid within six months of this law’s entering into force. • Starting from 1 July 2008, the minimum and maximum – Taxpayers that are prosecuted and found guilty will not salary levels for the purpose of calculating social benefit from the amnesty. security and health contributions have increased to ALL 14,830 (approx. EUR 122) and ALL 74,150 (approx. EUR 609), respectively. PricewaterhouseCoopers 2 CEE Tax Notes 2008/3 Armenia Tax administration reform Indirect taxation A Tax Administration Strategy Programme for 2008-2011 VAT has been unveiled, with the aim of creating a more efficient and transparent tax administration. The seven goals of the • Several changes in VAT will take effect from initiative are to: 1 January 2009. – Ensure complete, consistent and timely taxation of large • The annual revenue threshold requiring monthly taxpayers; VAT reporting will increase from AMD 60 million – Establish a low but fair tax burden for small businesses, (approx. EUR 140,000) to AMD 100 million with minimised reporting and filing requirements; (approx. EUR 240,000) per year. – Address corruption in the State Tax Service; – Fully introduce the principle of voluntary compliance • Businesses with sales exceeding AMD 58.35 million (self-assessment), minimising contacts between taxpayers (approx. EUR 140,000) in the preceding calendar year and tax officials..
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