Latest News

• 

  EXCLUSIVE: Transparency, trade and tax: a G8 action plan

  May 22, 2013

  Jeffrey Owens, the OECD’s former head of tax, and Mick Moore, of the University of Sussex, believe their 10 point action plan for the G8 summit next month could achieve fairer taxation of multinationals, improve tax transparency and help developing countries build up their tax capacity.

• 

  What you have missed on ITR Premium

  May 20, 2013

  Australian budget; Brazil income tax exemptions; Dutch Supreme Court tax ruling; Germany DTA arbitration; France invoicing; Croatia’s EU membership; Tax compliance rules; FATCA

• 

  How taxpayers should manage their global disputes

  May 20, 2013

  International Tax Review has produced tax disputes reference guides for 26 countries. The guides look at how multinationals can avoid and manage tax disputes in each jurisdiction as well as offering insight about the future litigation strategies of individual tax authorities.

• 

  Winners of European Tax Awards 2013 revealed

  May 16, 2013

  Rosneft, the Russian energy company, was named as European in-house team of the year for direct tax at International Tax Review’s European Tax Awards last night.

• Read about the next Global Transfer Pricing Forum

  May 16, 2013

  The next Global Transfer Pricing Forum will take place in New York on September 18th and 19th.

• 

  OMB controller joins IRS as acting commissioner

  May 16, 2013

  President Obama has appointed Daniel Werfel as acting commissioner of the Internal Revenue Service.

• 

  Brazil’s income tax exemption on dividends

  May 14, 2013

  Cristiane Magalhães and Fernanda Fiasco Ribeiro, of Machado Associados, explore a recent opinion (Opinion 202/2013) issued by the Office of the Attorney General of the National Treasury (PGFN) about the tax exemption applicable to the distribution of profits and dividends established by Article 10 of Law 9249/95.

• 

  Brazil’s new policy on ICMS and VAT benefits

  May 14, 2013

  There is a new federal programme which promises a fresh landscape for tax benefits in Brazil.

• 

  Baucus and Camp diversify tax reform approach with new website

  May 14, 2013

  The main driving forces behind tax reform attempts in the US Congress - Max Baucus and Dave Camp - have launched a new website to increase stakeholder engagement in the tax reform process.

• 

  What you have missed on ITR Premium

  May 13, 2013

  Australian industry group wants tax cuts; CBI proposes tax principles; Finnish MAP; expert evidence in Canadian tax cases; indirect tax hikes in Japan; US Marketplace Fairness Act; Rand Paul on FATCA

• 

  Mexican Supreme Court rules on relief of tax losses derived from alienation of shares

  May 07, 2013

  Last month, the Mexican Supreme Court of Justice (MSCJ) solved several appeals of constitutional rights filed against Article 32, Section XVII, of the Mexican Income Tax Law (MITL).

• 

  Mexican taxpayers given opportunity to settle disputes under amnesty programme

  May 07, 2013

  Fernando Lorenzo Salazar, of PwC Mexico, explains how taxpayers can make the most of Mexico’s tax amnesty programme (TAP) to settle their disputes.

• 

  Canada Revenue Agency’s access to foreign-based information

  May 02, 2013

  Deborah Toaze, of Blake, Cassels & Graydon, looks at what a Federal Court (Canada) (FC) ruling means for the Canada Revenue Agency’s (CRA) ability to obtain foreign-based information from taxpayers.

• Guernsey commits to automatic exchange of tax information

  May 01, 2013

  One of the UK’s Crown Dependencies, with which Britain has recently agreed new plans to improve tax reporting, has come out in favour of a pilot programme for introducing an international system of multilateral exchange of information.

• 

  Tax: Law and morality - which way now?

  April 30, 2013

  International Tax Review magazine editor Salman Shaheen will chair an IF Campaign debate with UK Exchequer Secretary David Gauke and other members of Parliament on the impact of tax avoidance on developing countries.

• 

  Max Baucus retires: What next for US tax reform?

  April 30, 2013

  Max Baucus, Senate Finance Committee chairman, has decided to not seek re-election and opinion is divided over whether this announcement improves or hampers the prospects for a comprehensive reform of the US tax code.

Latest Magazine Issue

Archive  Search  More Magazine

Latest Issue May 2013

The world is changing: The gradual evolution of tax planning

The world of tax planning is changing, bringing new risks and challenges for taxpayers. The change may be gradual, but companies should not ignore how significant it is.

Features

• Luxembourg’s plan for AIFMD puts tax in the spotlight

  

  Laetitia Borucki of Bonn Steichen & Partners believes fund managers should review the potential tax impacts relating to residency, VAT and carried interest that are included in Luxembourg’s draft law to implement the EU Alternative Investment Fund Managers Directive. The creation of a new type of partnership is also to be considered.

• Transparency: A little information is a dangerous thing

  

  As was recently acknowledged by Monica Bhatia, who heads the OECD’s Global Forum on Transparency and Exchange of Information, “we are seeing a rise in tax transparency, and it’s only going in one direction: more transparency”. Mark Friezer, partner at Clayton Utz in Sydney, explores the latest disclosure requirements being imposed on taxpayers in Australia.

• FIBRAs insight: Towards a decade of Mexican REITs

  

  As we approach the 10-year anniversary of real estate investment trusts (FIBRAs/REITs) being introduced in Mexico, Alfredo Sánchez and Roberto Padilla Ordaz of Chevez, Ruiz, Zamarripa y Cia track the regime’s development and explain why these investment vehicles have become more attractive in recent years.

• Unitary taxation with combined reporting: The TP solution?

  The OECD’s Base Erosion and Profit Shifting (BEPS) project issued a report in February 2013, which confirmed that the present international tax rules are not effective: “There is increased segregation between the location where actual business activities take place and the location where profits are reported for tax purposes.” David Spencer, formerly a senior adviser and head of transfer pricing for the Tax Justice Network, explores the viability of unitary taxation and questions whether it is a realistic option, considering the way international commerce operates.

• Recent transfer pricing developments in Poland

  

  Aneta Blazejewska-Gaczynska of Ernst & Young looks at how recent hearings from the Polish courts and the planned changes to the law affect transfer pricing

• The rise of carbon pricing in the BRICS

  Carbon pricing is increasingly becoming part of the BRICS’ strategy to tackle climate change. Emma Powell examines how these countries are implementing it and what effect it will have on businesses.

• EU VAT reform could go much further

  

  Stuart Adam and David Phillips of the UK Institute for Fiscal Studies argue that the EU’s VAT reform plans could go much further in looking to abolish exemptions and reduced rates.

• Portuguese VAT anti-abuse rules

  The increasing sophistication of transactions performed between taxpayers has raised concerns among legislators about the recurrent manipulation of the terms and conditions of such transactions as a way of reducing the tax impacts, thus distorting the objectives of the tax systems. Rui Guedes Henriques, Tiago Almeida Veloso and Ana Filipa Janine of Baker Tilly look at the VAT anti-abuse rules introduced in the 2012 budget to address these concerns.

• Amendments to TP legislation and new informative return

  

  Roberto Carlos Rivas, Carolina Alexandres and Gabriel Bernal of PwC look at the changes to transfer pricing legislation which came into force in September last year.

• Why taxpayers should not withdraw claims after Wheels

  

  Nick Skerrett and Matthew Rees, of PwC, explain why the European Court of Justice’s (ECJ) ruling in the case of Wheels Common Investment Fund Trustees v HMRC means the question of VAT on investment management fees in the context of pensions remains unresolved and why taxpayers should not withdraw their claims just yet.

• International mismatches: BEPS and a Danish example

  

  Jens Wittendorf, of Deloitte Denmark, examines a recent dispute in the National Tax Tribunal (NTT) which highlights how unilateral anti-hybrid legislation can have the unintended consequence of eroding the domestic tax base.