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  • EU progresses towards FTT

    Europe is rarely as united on tax policy as the Commission would like it to be, but few issues are more divisive than the financial transaction tax (FTT). Salman Shaheen assesses the prospects of an EU-wide FTT, what it will mean for taxpayers and whether it remains the best option for making the financial sector pay for its role in the economic chaos.


Features

  • How the Home Concrete ruling has hampered the IRS

    US taxpayers breathed a collective sigh of relief in April when the Supreme Court delivered its verdict in Home Concrete which stated that the Internal Revenue Service (IRS) was not permitted to use an extended six-year statute of limitations period to investigate overstatements of basis. But there was a broader issue at stake in the case – the IRS’s ability to issue regulations and apply them retroactively. Joe Dalton explores the wider implications of Home Concrete and why US taxpayers will be hopeful the ruling will diminish the IRS’s arsenal in avoidance cases.

  • Why joint audits are yet to take off

    Last June, International Tax Review looked at the concept of joint auditing while the mechanism was still in its infancy. One year on, Matthew Gilleard assesses how things have progressed and if we have any clearer idea of whether the process works in reality.

  • SABIC explains how to get the most from China

    Jack Grocott speaks to Watson Wang, SABIC’s new head of Asia-Pacific tax, about the role of a tax director in China, how to create certainty and to manage effectively a working relationship with the increasingly aggressive tax officials.

  • Taxpayers and advisers claim their European awards

    The eighth European Tax Awards were notable for the in-house awards that went to companies with media and entertainment roots

  • Transfer pricing is recurring issue at Asia forum

    The 2012 International Tax Review Asia Tax Forum, held in Singapore, once again attracted scores of tax professionals from throughout the Asia-Pacific region and beyond. While transfer pricing was high on the agenda, it was not the only concern and other panels included: keeping in step with Chinese rules changes; establishing trust between officials and taxpayers; dealing with developing tax systems; the Indian reform; cross-border issues; dispute resolution; improving effectiveness in the tax department through technology; and indirect tax.

  • New restriction on interest deductibility on acquisition debt

    Olivier Parawan, of Mayer Brown, assesses the new Carrez Amendment provision of French tax law, and explains how the interest deduction limitation could affect your business.

  • US tax treaty shopping rules: Traps for the unwary

    Income tax treaties can provide significant protections for European investors and businesses in the US. As Congress seeks to close tax loopholes, to generate additional revenue, users of US tax treaties may face even tighter anti-treaty-shopping rules, warn Alfred Groff, Kristen Garry and Nathan Tasso, of Shearman & Sterling.

  • Understanding Indian infrastructure taxation

    The infrastructure industry is booming in India. But with a raft of tax law changes and a government keen to garner higher taxes from investors, Samir Kanabar, of Ernst & Young offers some insight into key challenges of undertaking an infrastructure project in India.

  • Newly modified Brazilian CUPs: Bad policy remains

    Napoleão Dagnese head of international tax at OC Oerlikon, a high-tech industrial company, provides a critical analysis of the changes to the Brazilian transfer pricing regime, from the taxpayers’ perspective.

  • An opportunity to support US customs valuations

    Harmonising a company’s transfer pricing documentation with customs requirements has always been a contentious issue because of the inconsistencies between the two regimes. David Grace, Emin Toro and Mateo Caballero from Covington & Burling explain how taxpayers can make this process easier.

  • Why Ireland won’t budge on corporate tax cut

    Irish leader Enda Kenny signed up to the EU's fiscal compact on tighter budgetary controls in March, but this should not be taken as a sign the country will agree to EU harmonisation over corporate tax rates.

  • Irish loan portfolio sales and acquisitions

    Conor Hurley and Jonathan Sheehan of Arthur Cox explain why Ireland is the ideal location for investment and explain why the country’s tax regime makes it the best location for structuring an acquisition, whether Irish or international.

  • Executive remuneration in Ireland

    The issue of executive remuneration is a hot topic around the world with governments keen to reduce executive packages and bonuses. Olivia Lynch of KPMG explains how Ireland is treating this topic through the use of the recently introduced special assignee relief programme and why the country wants to be the number one destination for foreign direct investment in Europe.

  • International tax planning and anti-avoidance

    With governments seeking to raise additional tax revenues to plug budget deficits, tax authorities are seeking to introduce and apply general anti-avoidance (GAA) legislation. Robert Henson and David Burke of Mason Hayes & Curran explain why a recent Irish Supreme Court decision has implications for multinational corporates doing business in and through Ireland.

  • Why Ireland continues to attract asset management business

    Martin Phelan and Niamh Keogh of William Fry Tax Advisors – Taxand describe how Irish fund structures achieve tax neutrality, and the relatively few administrative hurdles that exist.

  • The advantages of automating VAT

    Eric Ruud, senior vice-president and general manager, ONESOURCE Indirect Tax for the Tax & Accounting business of Thomson Reuters, looks at how companies can better manage their global indirect tax determination and compliance processes.

  • Smart carbon pricing is the best way to meet budget deficits

    Jacqueline Cottrell of Green Budget Europe introduces a new report which finds that carbon taxation is not only good for the environment, but national deficits too.

  • More to EU place of supply rules changes than meets the eye

    Adam Peacock and Mark Agnew of Baker & McKenzie look at what the 2015 changes to the EU place of supply rules will mean for business-to-consumer (B2C) suppliers.

  • Brazil issues new transfer pricing rules

    Luiz Felipe Centeno Ferraz, Alessandro Amadeu da Fonseca and Antonio Carlos Marchetti Guzman of Mattos Filho Veiga Filho Marrey Jr e Quiroga Advogados analyse the recently updated Brazilian transfer pricing rules and offer insight into what it means for multinational taxpayers.

  • SCC upholds new test for residency of trusts

    Ed Kroft QC and Jeffrey Shafer of Blake, Cassels & Graydon analyse the recent Supreme Court of Canada St Michael Trust Corp ruling and explain why the court’s decision has several implications for taxpayers.

  • The risks of doing business in Vietnam

    Vietnam has recently had a number of relatively high-profile tax disputes which serve to highlight trends across a number of industries and areas. Tom Prescott of Grant Thornton Vietnam explains what these cases mean for the future of complying with the country’s tax laws.


News Analysis


People


Editorial


Tax Relief

  • Tax Relief

    A monthly commentary on the notable facts, figures and goings-on in the tax world. Suitable items should be sent to taxrelief@euromoneyplc.com


International Correspondents


Which possible outcome of the G20 / OECD BEPS project would carry the biggest fear for your company?