August 29, 2017
The seventh edition of the Tax Controversy Leaders guide has been released, with more than 300 new names and seven additional countries this year.
August 23, 2017
The tax status and characterisation of passive holding companies has gained renewed interest with Article 7 of the OECD’s Multilateral Instrument (MLI) containing some reference to these entities. Mauro Manca of Giovannelli e Associati looks at how these structures can still work if there are sound organisational reasons in the MNE structure.
August 21, 2017
Sports Direct has won an appeal ruling against the UK tax authorities in a VAT case concerning de-coupling. Adam Peacock of Baker McKenzie looks at why the company won and what this decision means.
August 18, 2017
Following Chevron’s settlement with the Australian Tax Office (ATO) over its transfer pricing dispute, are governments and the OECD-led global initiatives now taking the appropriate actions to tackle tax avoidance once and for all?
August 16, 2017
A tax battle with Google is clearly not enough for the French tax authority. Now it is engaging British drinks giant Diageo as it tries to shut down the tax advantages of multinationals.
August 09, 2017
Companies using employee benefits trusts to reward their employees need to review their structures after the first ruling from the UK’s GAAR panel went in favour of HMRC and reinforced the Supreme Court’s decision in the Glasgow Rangers case.
August 08, 2017
Salman Shaheen speaks to Rudolf Elmer, the whistle-blower who has been fighting a long court battle after revealing on WikiLeaks the activities of his former employer, Swiss bank Julius Bär, in the Cayman Islands.
August 07, 2017
Eaton, a diversified power management company and global technology leader in electrical systems, won a landmark transfer pricing case against the US Internal Revenue Service. Mike Patton and Mumi Hemrajani of DLA Piper US discuss the implications of this first occasion when a taxpayer has judicially challenged an APA revocation or cancellation.
August 02, 2017
The European Commission (EC) has made the next move in a long-running state aid dispute over corporate tax exemptions for ports, by telling France and Belgium to abolish the exemptions in order to align their tax regimes with EU law.