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Tax Disputes

Tax Disputes archive
  • Companies set aside billions as risk of UK tax disputes rise

    September 18, 2017

    UK FTSE 100 companies are putting more money aside than ever before to deal with the cost of tax litigation. These figures come a few days after the UK tax authority said it has yielded £312 million since the diverted profits tax (DPT) regime was introduced in 2015.

  • Americas Tax Awards 2017 winners announced

    September 15, 2017

    The top tax and transfer pricing experts from across the Americas congregated at the Pierre Hotel, New York, on September 14 to honour the very best firms and individuals across a host of categories. Check out the winners here.

  • Tax authorities hone in on banks’ tax avoidance strategies

    September 13, 2017

    French bank BNP Paribas paid HMRC millions for ‘dividend stripping’ before a court ruled against the bank on the tax avoidance case. But this is just one case across four continents of such tax abuse.

  • France tries to use PE rules to make MNEs pay a ‘fair share of tax’

    September 05, 2017

    The French permanent establishment rules are the country’s biggest hurdle in taxing Google, Amazon, Facebook and Apple (GAFA) in the way it wants. But it is determined to use these rules to make such digital companies pay what it believes to be their ‘fair share of tax’.

  • 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.

  • Long battle ahead as IRS challenges US Medtronic verdict

    July 28, 2017

    Medtronic is being forced to defend its transfer pricing practices again after the IRS launched an appeal on the 2016 ruling. But after concluding a decade-long court dispute last year, how long could this latest challenge take?

  • EU case to set precedent on VAT treatment of rebates for parties outside the distribution chain

    July 27, 2017

    The ECJ will soon rule on a case involving global pharmaceutical company Boehringer Ingelheim that will set a VAT precedent for the pharmaceutical sector. Jan Sanders, indirect tax manager at RELX, discusses the impact of a ruling on this long-debated matter concerning the VAT treatment of supplies outside a distribution chain.

  • Acacia’s $190 billion Tanzania tax bill sends shockwaves through mining sector

    July 25, 2017

    In a situation that could not get much worse for Tanzania’s biggest mining company, Acacia Mining has been handed a tax bill for $190 billion in alleged unpaid taxes and penalties by the government – an amount larger than the combined tax payments of the top five global gold miners since 2000.

  • HMRC hails success of controversial APNs

    July 21, 2017

    UK tax authority HM Revenue and Customs (HMRC) has won every court challenge against its controversial accelerated payment notices (APNs) issued to individuals and businesses under enquiry for tax avoidance.

  • Americas Tax Awards 2017: Shortlists announced

    July 19, 2017

    The nominees for the 12th annual Americas Tax Awards have been announced.

  • German Fiscal Court on the dilemma of tax neutrality for funds and equal treatment under the EU freedoms

    July 18, 2017

    Under its tax regime, Germany grants a tax exemption only for domestic funds but not for foreign funds. The Fiscal Court Münster (20/04/2017,10 K 3059/14 K) ruled that this is in line with the EU freedoms because the situation of German funds is not comparable to that of foreign funds.

  • Google not out of the woods after landmark $1.25 billion French court victory

    July 14, 2017

    After a six-year tussle, Google has emerged victorious after the Paris administrative court found in its favour over a PE dispute. But the French authorities have announced their intention to appeal.

  • European Tax Awards 2017: Winners announced

    July 11, 2017

    Over 30 different firms and individuals won recognition for their unique achievements at this year’s European Tax Awards 2017 held at The Savoy, London.

  • The economics behind EU tax investigations: The way forward

    July 11, 2017

    The European Commission has made some surprising decisions in recent years about how tax rulings between multinationals and EU member states constitute state aid. In the second of this two-part series of articles, Carina Lange, senior consultant at CEG Global in the Netherlands, discusses how multinationals can maintain legal certainty and assess the risks associated with tax rulings.

  • HMRC scores against Glasgow Rangers in Supreme Court

    July 07, 2017

    HMRC has triumphed in its five-year dispute with Scottish football club Glasgow Rangers over the use of employee benefit trusts (EBTs) to avoid taxation. The case gives the UK tax authority a golden ticket to go after other individuals and companies that have used similar structures, but not all cases are likely to be easy wins for the tax authority.

  • Levy of IRRF and CIDE on the remuneration of software as a service (SaaS)

    July 04, 2017

    The Brazilian Federal Revenue Service (RFB) has issued an unprecedented ruling regarding the levy of the withholding income tax and contribution for intervention in the economic domain (CIDE) on the remuneration for the authorisations for remote access and use of software as a service (SaaS).

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International Tax Review Profile

South Africa's tax authority may launch legal proceedings against KPMG https://t.co/t3kBwe2ZyP via @business

Sep 18 2017 03:41 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @Brigard_Urrutia: .@IntlTaxReview reconoce a @Brigard_Urrutia como la mejor firma colombiana en Impuestos 2017. #AmericasTaxAwards2017 h…

Sep 18 2017 09:58 ·  reply ·  retweet ·  favourite
International Tax Review Profile

Tanzanian president's war on "tax cheats" is rattling investors https://t.co/UyQOYVahYT via @business

Sep 18 2017 08:44 ·  reply ·  retweet ·  favourite
International Tax Review Profile

See all the winners from our Americas Awards here: https://t.co/MhksIMkToP. Well done to you all!

Sep 15 2017 03:53 ·  reply ·  retweet ·  favourite
International Tax Review Profile

KPMG chiefs in South Africa quit amid Bell Pottinger scandal https://t.co/awBFqobdF9

Sep 15 2017 03:52 ·  reply ·  retweet ·  favourite
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