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Tax Disputes

Tax Disputes archive
  • Big 4 and law firms share the spotlight at Americas Tax Awards 2014

    September 19, 2014

    The big winners at this year's Americas Tax Awards were EY, which won the Latin America Tax Firm of the Year and Shearman & Sterling, the winner of the equivalent award for North America.

  • ECJ gives verdict on VAT treatment for the delivery of e-books

    September 19, 2014

    In the Finnish K Oy case on the VAT treatment of digitally published books, the ECJ ruled that if a typical consumer in the EU treats the product the same as it would a physical book then the same rate of VAT should be applied.

  • Landmark ECJ ruling sees financial institutions’ VAT bill increase

    September 17, 2014

    Banks, insurers and other financial institutions across Europe will see their VAT costs soar into the hundreds of millions, following a decision by the European Court of Justice, which makes services supplied between a financial services group’s headquarters and subsidiaries subject to VAT.

  • Court of Appeal rejects UK attempt to re-open FII litigation arguments

    September 16, 2014

    The Court of Appeal in London has decided the UK tax authorities should not be allowed change their defence in the Franked Investment Income Group Litigation on the issue of liability as that aspect of the case has already been finalised.

  • The tax market reacts to the BEPS 2014 deliverables: Do you agree?

    September 16, 2014

    The OECD today unveiled its 2014 deliverables at the halfway stage of the multilateral organisation’s ambitious base erosion and profit shifting project, commissioned by the G20, which represents the biggest ever review of international tax rules.

  • GMAC’s strategy for limiting VAT payments proved lawful in ECJ

    September 12, 2014

    Robert Waterson and Nigel Brook of RPC explain why the decision of the European Court of Justice (ECJ) in the GMAC case (HMRC v GMAC UK plc C-589/12) represents a comprehensive win for the taxpayer.

  • ECJ rules in favour of GMAC in VAT bad debt relief claim

    September 11, 2014

    The GMAC decision in the European Court of Justice (CJEU) should give taxpayers the courage to look for benefits from inconsistencies in member states’ VAT legislation, advisers believe.

  • World's leading tax controversy advisers unveiled

    September 05, 2014

    The fourth edition of International Tax Review's Tax Controversy Leaders guide is out now. Find out who the top-rated disputes specialists are in your jurisdiction.

  • Argentine Supreme Court: Must grossing-up be considered for VAT purposes?

    September 04, 2014

    In re Puentes del Litoral the Argentine Supreme Court analysed whether, in a cross-border transaction agreed with grossing-up, the amount of the income tax assumed by the local party has to be considered for value added tax (VAT).

  • Brazil: ICMS tax reform gets closer but war is still not settled

    September 04, 2014

    The row over the ICMS tax between taxpayers and the Brazilian states and legislature is still not resolved. Renata Correia Cubas, of Mattos Filho Veiga Filho Marrey jr e Quiroga explains the issues behind the conflict.

  • HMRC granted leave to appeal in Rangers FC EBT case

    September 03, 2014

    HM Revenue & Customs has been allowed to challenge the ruling over Glasgow Rangers Football Club’s use of employee benefit trusts (EBTs), which it used to pay players and staff.

  • Alternative dispute resolution: Alleviating burdens all round

    August 29, 2014

    The number of tax disputes is increasing rapidly around the world. The trend is encouraging governments to turn to alternative dispute resolution (ADR) in a bid to reduce backlogs in the courts. While ADR is well established in some jurisdictions, in others it is just getting going. Aaran Fronda looks at how ADR has become an increasingly viable solution for resolving tax disputes.

  • Verizon claims IRS arguments are inconsistent in $26 million WorldCom case

    August 29, 2014

    The US Supreme Court is mulling over whether or not to hear WorldCom Inc v. Internal Revenue Service (13-1269), a case that holds the now-obsolete WorldCom (Verizon Communications) liable for millions in excise taxes for its telecommunications services.

  • Indian High Court provides relief for indirect transfer of Indian assets

    August 28, 2014

    The Delhi High Court’s ruling in the Copal Research Limited, Mauritius case is the first on the taxation of the indirect transfer of Indian assets since the previous government’s much talked about amendment following the Supreme Court’s Vodafone decision.

  • New protocol to Canada-UK tax treaty could affect future tax disputes

    August 26, 2014

    Jeffrey Shafer and Ian Caines, of Blake, Cassels & Graydon, explain how the recent protocol to the Canada-UK tax treaty could induce a change in the way taxpayers approach disputes covering the two jurisdictions.

  • HMRC to close EBT settlement initiative

    August 21, 2014

    UK taxpayers have until March 2015 to eliminate employee benefit trusts (EBT) from their tax planning. However, the warning does not apply to every company that has used the technique, advisers say. A settlement initiative for employers who used Employee Benefit Trusts (EBT), as a tax avoidance vehicle will close in seven months’ time, HM Revenue and Customs (HMRC) has announced.

  • TEI raises concerns about Chinese GAAR

    August 21, 2014

    The Tax Executives Institute (TEI) submitted comments to China’s State Administration of Taxation (SAT) regarding its draft of administrative measures on general anti-avoidance rules (GAAR). The group, which represents the interests of in-house tax professionals, expressed concern that the new measures inappropriately expand the scope of GAAR and do not provide clarity to taxpayers.

  • Americas Awards nominations released

    August 20, 2014

    The nominations for the Americas Tax Awards, which take place in New York on September 18, have been announced on

  • India: High Court rules CCDs are exempt under India-Mauritius DTAA

    August 14, 2014

    The Delhi High Court has decided, in Zaheer Mauritius vs Director of Income Tax, that the sale of compulsory convertible debentures (CCDs) should be classified as capital gains and exempt under the India-Mauritius double tax treaty (DTT). The decision will mean most to real-estate taxpayers who use Mauritius to invest in India.

  • Phase II of AJAC may increase US litigation

    August 13, 2014

    Phase II of the Appeals Judicial Approach and Culture (AJAC) project in the US provides that the Appeals division of the Internal Revenue Service will not accept new cases unless there is at least 365 days remaining on the statute of limitations, but this may lead to more cases heading for litigation.

  • Brazil: Tax amnesty programme applied for Rio de Janeiro

    August 07, 2014

    The amnesty programme allows the waiver or reduction of penalties and interest relating to certain outstanding state tax obligations in a bid to increase tax revenue.

  • Amazon struggles to resolve $1.5 billion dispute with IRS

    August 06, 2014

    The international e-commerce company, Amazon, has failed to resolve elements of its transfer pricing dispute with the Internal Revenue Service (IRS). The case revolves around the retailer’s use of a European subsidiary to reduce its tax bill which, if it loses, could cost the company billions.

  • HMRC to get even tougher on tax avoidance

    August 06, 2014

    New proposals by the UK government to enlarge the scope of its Disclosure of Tax Avoidance Schemes (DOTAS) and VAT Avoidance Disclosure Regulations (VADR) regimes, as well as the drafting of a new financial product hallmark, will increase the number of schemes that could fall prey to controversial accelerated payment powers.

  • Argentine Supreme Court disables ARBA’s extra-territorial powers

    July 30, 2014

    The Revenue Department of Buenos Aires (ARBA) attempt to freeze assets in taxpayers’ bank accounts and impose sanctions on financial institutions to obtain account holder information, which lay outside their jurisdiction, is unconstitutional without court approval, the Supreme Court of Justice (SCJ) has decided.

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International Tax Review Profile

Lew Says ‘More to Say’ Later Today on Tax Inversions - Bloomberg via @BloombergNews

Sep 22 2014 08:46 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @damianpaletta: Lew, in speech, to confirm @WSJ scoop that details of White House inversion plan are coming later on Monday.

Sep 22 2014 08:42 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @taxfoundation: The U.S. Ranks 32nd Out Of 34 OECD Countries In Tax Code Competitiveness via @forbes

Sep 22 2014 08:41 ·  reply ·  retweet ·  favourite
International Tax Review Profile

#GlobalTP2014 moves on to session about hot topics other than #BEPS

Sep 22 2014 08:41 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @Sorainen_tax: International Tax Review TP Week World Transfer Pricing Guide 2015: SORAINEN - the Top tier TP firm in the Baltics: http:…

Sep 22 2014 08:38 ·  reply ·  retweet ·  favourite
International Correspondents

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