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March 2012
March 30, 2012
Victory for Li & Fung in its battle with the Inland Revenue Department (IRD) has given much relief to companies which subcontract services to foreign affiliates.
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March 29, 2012
A second Russian thin capitalisation ruling in as many months has created new risks in debt financing structures where the lender is the foreign sister company.
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March 29, 2012
Chemical company Union Carbide (UC) begins its battle against the IRS in the 2nd US Circuit Court of Appeals today, where victory for the taxpayer could expand the scope of US research and development (R&D) tax credits.
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March 29, 2012
The European Commission has referred Germany to the ECJ for excluding non-resident companies from beneficial group taxation arrangements, and the anticipated change in German law will come as a relief to foreign companies.
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March 28, 2012
The decision to introduce a general anti-avoidance rule (GAAR) in India has not been welcomed by the country’s tax advisers, citing that it disrespects and challenges the country’s judicial system.
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March 22, 2012
A recent Dutch Court of Appeal ruling could see thousands more taxpayers claiming full refunds on dividend withholding tax and even lead to abolition of withholding tax on dividends, warn advisers.
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March 22, 2012
A novel approach to proving its actions did not provide a tax benefit helped Futuris win its Full Federal Court (FFC) dispute against the Australian Taxation Office (ATO) this week, but the outcome could have been different if the proposed amendments to Australia’s general anti-avoidance rule (GAAR) had applied in the case.
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March 22, 2012
A tax dispute involving the world’s second largest mining company, Vale, and the Brazilian Federal Revenue Service (RFB), could overhaul Brazil’s approach to the taxation of overseas profits.
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March 16, 2012
The Indian government today proposed legislation that will allow it to retrospectively tax overseas mergers where an Indian asset is transferred. This move nullifies the recent Vodafone Supreme Court decision.
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March 14, 2012
India’s Central Board of Direct Taxes has issued stringent reporting requirements for liaison offices (LOs) which advisers believe will lead to disputes and protracted proceedings.
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March 14, 2012
The Channel Islands are defending their right to the UK’s low value consignment relief (LVCR) at a High Court judicial review this week, but their legal team say that regardless of the outcome, offshore mail-order businesses won’t be moving back to the UK.
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March 13, 2012
Australia is strengthening its general anti-avoidance rule (GAAR) to ensure it counters tax avoidance schemes that are carried out as part of broader commercial transactions.
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March 12, 2012
The Supreme Court of Canada is today hearing the St Michael Trust Corp dispute on the tax residence of a trust.
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March 12, 2012
With the UK government set to announce consultation on a proposed general anti-avoidance rule (GAAR) in next week’s budget, International Tax Review has compiled a special free pdf report on the developments surrounding its introduction.
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March 08, 2012
The UK High Court has ruled that where taxpayers have unlawfully paid VAT to a supplier, they are not entitled to bring claims against HMRC under UK law but may have the opportunity to claim under European law.
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March 08, 2012
The Dutch Supreme Court has ruled that currency exchange gains on loans to which the anti-base erosion rules apply are not liable to tax, though law changes could be enacted as a result of the decision.
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March 06, 2012
Non-residents should not underestimate their exposure to Canadian tax filing obligations, warn Jean Marc Gagnon and Emmanuel Sala of Blake, Cassels & Graydon.
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March 05, 2012
A First-tier Tribunal (FTT) decision that deals with the UK’s consortium relief rules and the non-discrimination article in double taxation conventions contains some positives and negatives for taxpayers.
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March 05, 2012
Hiring the right external advisers can be one of the most difficult jobs for a tax department.
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March 01, 2012
The European Commission has launched a public consultation on the double non-taxation of cross-border companies.
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March 01, 2012
The Spanish Supreme Court has made a decision which not only contrasts with that of France's Zimmer case and Norway's Dell case but means taxpayers should re-examine structures where a Spanish company performs activities for non-resident related entities under contract.
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March 01, 2012
Multinationals applying Canadian tax treaties to reduce withholding tax on royalty payments before paying funds to entities in non-treaty countries were boosted by a favourable Canadian Tax Court ruling last week.