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  • December 2013

    Six more FATCA intergovernmental agreements and details of data exchange announced

    December 20, 2013

    It has been a breathless time for the Foreign Account Tax Compliance Act (FATCA), the US law aimed at uncovering undisclosed money held by Americans in overseas banks.

  • Taxpayers are preparing for more transparency but fear the extra burden

    December 20, 2013

    Companies want more guidance and advice from tax authorities about how to manage tax transparency, a topic that is set to be key to the outcomes from the OECD’s BEPS project over the next two years. That was one of the more important findings from a survey of more than 100 global organisations.

  • Andrew Mills named second commissioner to the Australian Taxation Office

    December 19, 2013

    Arthur Sinodinos, Australia’s Assistant Treasurer, today announced the appointment of Andrew Mills as a full-time second commissioner to the Australian Taxation Office (ATO).

  • Baucus wants to halve available US energy tax breaks

    December 19, 2013

    Max Baucus, chairman of the US Senate Finance Committee, has released an energy tax reform discussion draft which would repeal many incentives (or allow them to expire) and replace them with two tax credits for the production of clean electricity and clean fuels.

  • IRS wins Woods argument in Supreme Court over gross valuation misstatements

    December 19, 2013

    The US Supreme Court handed down a unanimous verdict in the Woods case on December 3, where the Internal Revenue Service argued that the formation of a partnership to buy an offsetting-option tax shelter was only for tax avoidance purposes and so should be subject to a 40% penalty for gross valuation misstatements.

  • O'Brien makes partner at Jones Day

    December 19, 2013

  • The PAC verdict on HMRC: UK tax authority failing at its job

    December 19, 2013

    The UK Parliament’s Public Accounts Committee (PAC) has delivered its damning report on HM Revenue & Customs. Former HMRC tax inspectors agree. The UK tax authority is failing at its basic task and is not fit for purpose.

  • Twelve top picks from 2013's tax disputes

    December 19, 2013

    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

  • Late success for property developers in Germany

    December 18, 2013

    The German Federal Tax Court has put the Federal Ministry of Finance in its place, writes Thomas Küffner of KÜFFNER MAUNZ LANGER ZUGMAIER

  • Clifford Chance hires Olaf van der Donk

    December 17, 2013

  • Deals of the week - December 17 2013

    December 17, 2013

  • Enhanced relationship in developing countries depends on trust, confidence and transparency

    December 17, 2013

    Questions about what the concept of the enhanced relationship between taxpayers, officials and advisers should look like in developing countries, whether the idea would encourage voluntary compliance by taxpayers and what steps should be taken to enhance such a relationship, were raised during a panel discussion at the Foundation for International Taxation’s annual conference in Mumbai on December 6.

  • EU 11 mull narrower FTT

    December 17, 2013

    The 11 EU member states looking to adopt a financial transaction tax (FTT) have discussed proposals for a narrower version of the tax to get it past stalled negotiations.

  • Mauritius actively cooperating with India over tax treaty amendments

    December 17, 2013

    Mauritius has agreed to insert a limitation of benefit (LOB) clause into its tax treaty with India, based on a threshold related to the level of company expenditure on the island nation.

  • New Netherlands agreement could open tax planning opportunities

    December 17, 2013

    The Dutch Ministry of Finance has announced that the Netherlands and Curacao have agreed the text of a new bilateral tax arrangement designed to avoid double taxation. The agreement could create new tax planning opportunities.

  • Widmer-Schlumpf talks up Swiss tax achievements in 2013

    December 17, 2013

    Talk about having a lot to deal with. If one finance minister was at the centre of most of the controversial tax issues in 2013, mainly to do with the exchange of tax information, it was Eveline Widmer-Schlumpf of Switzerland.

  • Morality versus legality in international taxation

    December 16, 2013

    Delivering an address on the morality versus legality debate at the Foundation for International Taxation’s December 5-7 conference in Mumbai, former Chief Justice of India SH Kapadia stated that in the Indian context, the discernible principles of law should prevail and not morality in a general sense.

  • Tax policy earns UK bronze in trade-friendly ranking

    December 16, 2013

    The UK has come third in a poll of countries that are best-placed to capitalise on a boost in international trade.

  • Coleman moves to Ropes & Gray in London

    December 13, 2013

  • European Court of Justice says UK method of limiting reclaims in FII group litigation is unlawful

    December 13, 2013

    British legislation withdrawing a method of recovering tax charged in breach of EU law, “without notice and retroactively”, is against EU law, the European Court of Justice decided today in its verdict in the Franked Investment Income Group Litigation case.

  • Irish High Court ruling saves Denis O'Brien €57 million in tax

    December 13, 2013

    On September 6 2013 the High Court in Dublin upheld an appeal commissioner's decision in favour of Irish businessman, Denis O'Brien. The appeal commissioner had ruled that O'Brien was not liable to pay more than €57 million ($79 million) in capital gains tax (CGT) arising on the sale of loan notes in BT Hawthorn Limited in December 2000 and on the disposal of certain other assets during the 2000/2001 tax year.

  • Temporary relief for Nokia in India as Delhi High Court permits sale of assets to Microsoft

    December 13, 2013

    After a string of disputes with the Indian Tax Department (Tax Department), Nokia India Private Limited (Nokia India Private Limited v Addt. Commissioner of Income-tax, Writ Petition (Civil) No. 6150/ 2013) (Nokia India) has finally been granted some relief by the Delhi High Court (High Court).

  • Department of Justice loses Kovacev to Steptoe & Johnson

    December 11, 2013

  • New Brazilian measure on interaction between IFRS and corporate tax may increase bills

    December 11, 2013

    Taxpayers should be aware that the period of tax neutrality related to the adoption of International Financial Reporting Standards (IFRS) in Brazil ended with the enactment of Federal Government Provisional Measure 627 on November 11.

  • UK Lords slam FTT that would make “losers of us all”

    December 11, 2013

    The UK House of Lords EU Subcommittee on Economic and Financial Affairs has declared that the financial transaction tax (FTT) could significantly damage the UK and the rest of the EU.

  • BEPS: The Australian perspective

    December 10, 2013

    David Bradbury, Assistant Treasurer of Australia until the September election, and the driving force behind Australia’s efforts to tackle base erosion and profit shifting (BEPS) over the past 12 months, discusses the progress he made while in office and outlines what the newly elected government must do to build on that.

  • FASB says it will consult on reducing complexity of FAS 109

    December 10, 2013

    The Financial Accounting Standards Board (FASB) in the US has acknowledged that certain parts of the standard used to account for income taxes cause problems for investors and other users.

  • Ryan and Altalex join up

    December 10, 2013

  • Deals of the week - December 9 2013

    December 09, 2013

  • Giles Salmond leaves Deloitte for Eversheds

    December 06, 2013

  • US Supreme Court will not hear arguments against New York sales tax

    December 06, 2013

    Earlier this week, the US Supreme Court declined Amazon and Overstock’s applications for a hearing in a case relating to a law requiring out-of-state vendors to collect sales tax on New York transactions when they use New York residents to solicit business within the state through websites.

  • HK Court of Final Appeal rules against tax commissioner in Nice Cheer case on unrealised revaluation gains

    December 05, 2013

    In a judgment in Nice Cheer Investment Limited FACV 23/2012, the Hong Kong Court of Final Appeal ruled that year-end unrealised revaluation gains from listed securities held for sale were not chargeable to tax in Hong Kong.

  • Stevens takes tax policy role at CIOT

    December 05, 2013

  • UK Autumn Statement: Osborne pledges to raise £9 billion from anti-avoidance measures

    December 05, 2013

    George Osborne, UK Chancellor of the Exchequer, today unveiled his Autumn Statement. Anti-avoidance measures dominated, with Osborne promising they will raise £9 billion ($15 billion) over five years.

  • Vodafone questions applicability of transfer pricing provisions at Bombay High Court

    December 05, 2013

    Last week’s Vodafone case at the Bombay High Court about the applicability of transfer pricing provisions applied to its transfer of shares with an overseas company was deferred to the Dispute Resolution Panel (DRP) in India.

  • Why seller pre-closing debt cleaning transactions are costly to buyer

    December 05, 2013

    John Leopardi and Emmanuel Sala, Blake, Cassels & Graydon explain why seller pre-closing debt cleaning transactions are costly to the buyer.

  • A Polish VAT revolution in progress: Part 2

    December 04, 2013

    In the second of a two-part series, Radoslaw Szczech and Dorota Pokrop of EY look at the major VAT changes that will come into effect next year.

  • Former Treasury and IRS counsel joins Covington & Burling

    December 04, 2013

  • Tax tips for international companies in the Netherlands

    December 04, 2013

    Only a few weeks to go before the start of the new year. This is the time to check whether taking action before January 1 2014 could give you a tax advantage. Here are 11 tax tips and points to note for international companies covering various Dutch tax areas.

  • US promises more IGAs for FATCA implementation

    December 04, 2013

    The Cayman Islands and Costa Rica have become the 11th and 12th jurisdictions to sign bilateral intergovernmental agreements (IGA) with the US for the implementation of the Foreign Account Compliance Act (FATCA). And soon there could be at least 28, which are being used as the mechanism to clamp down on undeclared assets held by US citizens with foreign financial institutions (FFIs).

  • Indian Finance Minister Chidambaram trumpets business-friendly approach

    December 03, 2013

    Palaniappan Chidambaram, India’s Minister of Finance, spoke exclusively to International Tax Review about India’s increasingly non-adversarial approach to taxation and reducing uncertainty in the corporate tax environment.

  • Indian Finance Minister: DTC is ready

    December 03, 2013

    Speaking exclusively with International Tax Review, Palaniappan Chidambaram, India’s Minister of Finance, revealed the long-awaited Direct Taxes Code (DTC) is ready and that he hopes to pass the DTC Bill before the end of this parliamentary term.

  • UK Autumn Statement: Osborne urged to focus on stability

    December 03, 2013

    The annual pre-Autumn Statement rumour mill for the UK has been churning furiously and issues such as avoidance, business rates, capital gains tax and employment taxes will all probably get at least a mention in Chancellor George Osborne’s speech. However, many advisers are expecting few changes and are hoping instead for stability and certainty to be the two overriding themes of the statement.

  • Deals of the week - December 2 2013

    December 02, 2013

  • Jerome Tse becomes partner of King & Wood Mallesons

    December 02, 2013

  • What you have missed on ITR Premium

    December 02, 2013

    Tax avoidance; tax treaty benefits; Verizon; Apple; Polish VAT; Australian carbon tax; Tax risk assessment; EC corporate tax rules

  • BEPS and recent developments in Australian corporate tax law

    December 01, 2013

    Whatever form and acronym it takes (a similar, though narrower, examination was conducted in the 1990s under the banner of harmful tax competition (HTC)), base erosion and profit shifting (BEPS) has been an underlying theme in international taxation for years. But only recently has it risen to the top of the international taxation and political agendas, no doubt accelerated by the tax planning opportunities opened up by the globalisation and mobility of commerce. With Australia poised to take on the presidency of the G20, David Bradbury, Assistant Treasurer until the September election, and a driving force behind much of Australia’s work on tackling BEPS, analyses the impact the country has had on this global debate, looking at the policies his government implemented to get to this stage, and how the new government can take things forward.

  • The case for stronger tax risk management strategies

    December 01, 2013

    David Franco, senior Latin America analyst at risk analysis company Maplecroft, explores the evolution of anti-avoidance measures in the region, explaining why multinationals must be prepared for greater scrutiny of their tax affairs in Latin American countries in a trend that follows what is happening in Europe and the US.

  • Ireland continues to play fair… and plays to win

    December 01, 2013

    Helen O’Sullivan, the president of the Irish Tax Institute, believes that while the Irish government’s International Tax Strategy Statement shows the importance of multinational investors to the economy, tax-competitive rules are as important to small and medium-size enterprises, who employ 70% of the country’s workforce.

  • Indonesia tax audit guideline for affiliated transactions

    December 01, 2013

    Over the past four years, the Indonesian Directorate General of Tax (DGT) has been placing great focus on the tax potential from related-party transactions within multinational groups of companies. The DGT has issued regulations on transfer pricing guidelines, developed its human resources, equipped itself with commercial database, and undertaken audits particularly when there are intercompany transactions. Sri Wahyuni of SF Consulting provides an overview of the changes and explains what taxpayers need to do to guard against audit.

  • European Commission discusses new VAT rules

    December 01, 2013

    Donato Raponi, head of the European Commission’s VAT Unit, discusses the new VAT rules applying from 2015 to telecommunications, broadcasting and electronic services and the publication of Commission guidelines on the practical functioning of the mini one-stop shop.

  • Is a 2° climate target from 2020 cost-efficient?

    December 01, 2013

    The Green Budget Europe Annual Conference discussed new approaches for environmental fiscal reform and emissions trading at the Swiss, EU and international level and honoured Professor Frank Convery as 2013 Environmental Fiscal Reformer of the Year, reports Constanze Adolf, director of Green Budget Europe’s Brussels office.

  • Verizon’s royalty ruling at Madras High Court could open Pandora’s Box

    December 01, 2013

    A ruling from the Madras High Court in India, in a case involving Verizon Communications Singapore, could have far-reaching implications after the court confirmed that payments made by Indian customers to Verizon for providing bandwidth/telecom services is taxable as royalty income both under Indian Tax Law and under the India-Singapore tax treaty.

International Tax Review Profile

Big Soda scores victory as Chicago-area tax repealed - could this be the beginning of the end of the sugar tax trend?https://t.co/PNuafWHy9K

Oct 12 2017 04:03 ·  reply ·  retweet ·  favourite
International Tax Review Profile

Ebay and Netflix pay total UK tax of less than £1.9m - How long until HMRC investigate their TP practices? https://t.co/VPPsT3aGMZ via @FT

Oct 12 2017 03:59 ·  reply ·  retweet ·  favourite
International Tax Review Profile

Panama Papers: German authorities carry out first raids in connection with tax leaks https://t.co/LgalVGGw0x via @dwnews

Oct 12 2017 03:49 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @ScoopOnTaxes: @Skynet This will not end well for humanity. https://t.co/jsxVwDoDc5

Oct 11 2017 12:02 ·  reply ·  retweet ·  favourite
International Tax Review Profile

Goverments will one day soon look at how to tax robots https://t.co/3ghYzRmw8x

Oct 11 2017 09:34 ·  reply ·  retweet ·  favourite
International Correspondents