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Tax Disputes Archive

  • August 2017

    The world’s best tax controversy leaders revealed

    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.

  • EU holding company structure in treaty shopping cases

    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.

  • Sports Direct emerges victorious over HMRC in VAT ruling

    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.

  • Will tax avoidance schemes come to an end?

    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?

  • Diageo falls victim to France’s tougher tax stance

    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.

  • Boost for HMRC after first GAAR ruling

    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.

  • Q&A: Swiss whistle-blower Rudolf Elmer poised to leak explosive new information on tax evaders

    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.

  • US Tax Court determines IRS abused its discretion in cancelling two APAs with Eaton

    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.

  • EU tells Belgium and France to abolish tax exemptions for ports

    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.

International Tax Review Profile

RT @BrigitteAlepin: So proud of the new book WINNING THE TAX WARS. Bringing together well-known tax experts, this book presents outstanding…

Dec 7 2017 04:08 ·  reply ·  retweet ·  favourite
International Tax Review Profile

REVEALED: The top 10 of ITR's #GlobalTax50 2017 is out now. Find it here: https://t.co/IXiaRrE3vH (subscription or free trial required)

Dec 7 2017 01:42 ·  reply ·  retweet ·  favourite
International Tax Review Profile

ITR has opened the submissions period for the European Tax Awards 2018. Full details here: https://t.co/WKBWijhBgt

Dec 6 2017 01:40 ·  reply ·  retweet ·  favourite
International Tax Review Profile

@aloysrigaut @AuroChardon @ElodieLamer @JeanComte @diego_bxl @bsmithmey @afpfr @pierremoscovici @EU_Taxud @EU2017EE… https://t.co/oS4sDvQtdL

Dec 5 2017 04:55 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @AuroChardon: Is this it? https://t.co/O1XhoWQw2F 17 #taxhavens, mostly tiny countries or emerging economies on the #EUblacklist? ❌Swit…

Dec 5 2017 02:25 ·  reply ·  retweet ·  favourite
International Correspondents