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Twelve top picks from 2013's tax disputes

19 December 2013

Ralph Cunningham - ITR

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It was not easy to confine this list to one dispute from each month. Cases we had to leave out included PPL in the US Supreme Court about the creditability of foreign taxes and the Prudential judgment in the UK Supreme Court on legal professional privilege

It is not easy to characterise the type of tax disputes that reached the world's courtrooms in 2013, apart from with the generality that they arose from differing views of taxpayers and officials about what legitimate tax planning is. Here is a selection of the ones covered on the tax disputes channel of International Tax Review.

Chinese 2012 tax rulings deliver mixed messages

Sanofi's Indian High Court win is good for Vodafone-type transactions
Canadian taxpayers to face more foreign-based information requirements in transfer pricing audits
ECJ ruling on holding companies joining VAT groups confirms BAA solution
Resource Capital ruling helps taxpayers with TARP valuations but ATO approach remains worrying
Vodafone defends position in UK and Indian tax disputes
Canada's Lehigh Cement ruling broadens scope of foreign anti-avoidance rule
Brazilian courts' changing analysis of tax planning
BB&T loses STARS case but ruling clouds legitimate tax planning rights in US

Authorities get information exchange warning as Cayman taxpayers get ATO ruling quashed
Business lobbies Putin to review tax authorities' powers of enforcement
HK Court of Final Appeal rules against tax commissioner in Nice Cheer case on unrealised revaluation gains

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US debt-equity

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