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  • Supreme Court re-enters anti-avoidance arena

    For Canadian taxpayers and tax professionals, the general anti-avoidance rule, or GAAR, is synonymous with uncertainty. A new Supreme Court case will address some of the inconsistencies that have developed in the 18 years since the country enacted it. Erin Kelechava speaks to lawyers and the Canadian Revenue Agency about the court cases that have developed the doctrine and where they think the interpretation of GAAR is headed.


Features

  • Supreme Court re-enters anti-avoidance arena

    For Canadian taxpayers and tax professionals, the general anti-avoidance rule, or GAAR, is synonymous with uncertainty. A new Supreme Court case will address some of the inconsistencies that have developed in the 18 years since the country enacted it. Erin Kelechava speaks to lawyers and the Canadian Revenue Agency about the court cases that have developed the doctrine and where they think the interpretation of GAAR is headed.

  • A time for tax transparency and clarity

    Enhanced tax information exchange and greater offshore compliance was the biggest outcome of the G20 summit of world leaders last April in London. The subsequent 12 months saw increased tax cooperation between governments and hundreds of international information exchange agreements signed. Jack Grocott discovers what all this means for multinational companies.

  • Is the X Holding judgment off the Marks?

    A European Court of Justice ruling has tax advisers debating if it diverges from the Marks & Spencer, a key judgment that also tackled whether a subsidiary's losses can be used to offset a parent company's profit in another member state. Esther Martin reports

  • Legal reforms grab taxpayers' attention after budget

    The interest for taxpayers in this year's Indian budget came in the proposals to amend existing legislation, such as source rules for non-residents and the tax treatment of a conversion into a limited liability partnership, reveal Vispi Patel and Rajesh Athavale of Vispi T Patel & Associates, Chartered Accountants

  • Tax reclaims could be over soon for portfolio investors

    The OECD has released a draft implementation package that provides for a streamlined withholding tax relief process. This package is likely to be influential in terms of how countries modernise the cross-border withholding tax relief process. It may result in the holy grail of tax relief at source through standardised documentation and electronic filing to be realised.

  • Authorities up the pressure on fraudsters

    If enacted, amendments to Spanish law will increase the penalties for tax fraud, such as a longer prison term and direct liability for companies, and give the tax authorities more time to investigate cases. However, the changes will also add uncertainty for taxpayers, explain Oscar Morales and Manuel Álvarez of Uría Menéndez

  • Britain catches up in holding company stakes

    Careful study shows that the UK has a lot of advantages as a holding company location, such as favourable withholding tax rules. At the same time, it has its complexities, which also need to be understood, explain Stephen Hales and Alistair Craig of Ernst & Young


News Analysis



Comment


Tax Relief

  • No time to talk tax

    A monthly commentary on the notable facts, figures and goings-on in the tax world.


International Correspondents


International Tax Review Profile

RT @OECD: #BEPS implementation: analyses of 7 countries' efforts to improve #tax dispute resolution mechanisms now available ➡ https://t.co

Dec 18 2017 03:30 ·  reply ·  retweet ·  favourite
International Tax Review Profile

Margrethe Vestager once again showing why she's in the #GlobalTax50 with today's announcement of an investigation i… https://t.co/ncyjcWUUE8

Dec 18 2017 01:07 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @JP_Owens: Delighted to see #WUGTPC featured in #GlobalTax50 by @IntlTaxReview https://t.co/CMax2lIkvU Congrats to other colleagues in…

Dec 18 2017 12:53 ·  reply ·  retweet ·  favourite
International Tax Review Profile

So, ITR readers. Will the US tax reform bill make it to Trump's desk by Christmas?

Dec 18 2017 11:17 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @EU_Competition: State aid: @EU_Commission opens in-depth investigation into the Netherlands' tax treatment of Inter IKEA https://t.co/b

Dec 18 2017 11:12 ·  reply ·  retweet ·  favourite
International Correspondents