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May 2012
May 31, 2012
India’s Authority for Advance Ruling has sent a warning that taxpayers will have to be more cautious in structuring and evaluating the tax implications of engineering, procurement and construction (EPC) contracts that involve offshore supply of equipments by foreign suppliers/EPC contractors to Indian parties.
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May 31, 2012
The South African Revenue Service (SARS) and National Treasury are discussing whether to amend tax legislation after SARS lost a recent Supreme Court of Appeal case in which a double tax avoidance agreement (DTA) was deemed to override domestic law.
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May 28, 2012
Danish taxpayers should be able to avoid withholding tax on reorganisations, after the National Board delivered a landmark ruling on deemed dividend distributions.
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May 28, 2012
A recent victory for Copesul in Brazil’s Superior Court of Justice (STJ) should encourage companies relying on provisions of Brazilian double tax conventions (DTCs) to cut their effective tax rates.
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May 24, 2012
The Canada Revenue Agency (CRA) recently released its responses to a series of transfer pricing questions posed by Tax Executive Institute (TEI) members at a liaison meeting in December in 2011.
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May 23, 2012
Six claimants in the Franked Investment Income Group Litigation Order (FII GLO) had their claims for corporation tax refunds reinstated today, after a UK Supreme Court ruling said retrospective legislation issued by HMRC was in breach of EU law.
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May 21, 2012
Sergio André Rocha, of Ernst & Young in Brazil, examines a recent decision concerning the interpretation of article 7 of Brazilian double tax conventions (DTCs).
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May 17, 2012
The German Federal Fiscal Court recently held that a treaty override by German tax laws might be unconstitutional. If the Federal Constitution Court disagrees, then taxpayers will need to safeguard that refund claims could be appealed.
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May 17, 2012
The US Tax Court has denied Hewlett-Packard the right to US tax deductions claimed as part of a scheme involving artificial generation of foreign tax credits. The judgment does not bode well for several banks involved in similar disputes.
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May 17, 2012
The level of tax litigation is getting higher, particularly in Asia, as multinational companies wrestle for ground with the revenue-hungry tax authorities.
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May 16, 2012
Simachal Mohanty, global head of direct tax at Dr.Reddy's Laboratories, a pharmaceutical company, tries to find the positives in the much-criticised Indian general anti-avoidance rule (GAAR).
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May 14, 2012
South Africa's Supreme Court of Appeal last week released the ruling in its first-ever international tax case.
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May 10, 2012
Thai airline company, Bangkok Airways, won its case in Thailand’s Central Tax Court last week, and the financing scheme under dispute could now be replicated by taxpayers across the country.
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May 10, 2012
The ECJ has today stated that French legislation that imposes withholding tax on French-source dividends distributed to foreign undertakings for collective investments in transferable securities (UCITS) is contrary to EU law.
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May 09, 2012
With the Indian Parliament this week approving the amended Finance Bill 2012, a precedent has been set. The legislature has the power to overrule the country’s judiciary through the use of retroactive law amendments. Read what India’s leading taxpayers, officials and advisers have to say on this latest development.
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May 09, 2012
HM Revenue and Customs’ (HMRC) anti-avoidance group has published six monthly disclosure statistics that show a marginal increase in the number of disclosures made by promoters.
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May 03, 2012
A US report claims that taxpayers are likely to lose tax disputes at the Supreme Court. Read the advice taxpayers need to know if they are to avoid being on the losing side.
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May 03, 2012
Brazilian mining company Vale was ordered to present a bond to the Brazilian Federal Revenue Service (RFB) last week, but the company remains confident it will win its dispute over taxation of foreign profits.