-
June 19, 2013
Tax planning by Bhoruka Engineering (Bhoruka) to avoid capital gains tax on a share sale which effectively transferred immoveable property between two entities has been deemed acceptable by the Karanataka High Court. Advisers say there is nothing to stop other taxpayers taking advantage.
-
June 19, 2013
Denmark’s largest listed company, Novo Nordisk, has been hit with transfer pricing adjustments of DKK 22 billion ($3.95 billion) by the Danish tax authority (SKAT) resulting in an increased tax bill of DKK 5.5 billion.
-
June 14, 2013
Vincent Pang, of KPMG, offers multinationals some guidance on reducing the risk of becoming involved in Chinese tax disputes, the options available for resolving disputes and the trends the Chinese tax authorities will follow in the next few years.
-
June 13, 2013
Renata Correia Cubas and Alessandra Gomensoro, of Mattos Filho, explain how using writ of payments benefits taxpayers paying debts in Brazil.
-
June 13, 2013
The Israeli tax authorities are claiming that medical technology firm Medinol owes between $150 and $225 million in capital gains tax on a $750 million compensation payout it received from US company Boston Scientific in 2005.
-
June 13, 2013
Domestic and foreign companies acquiring Brazilian entities through the incorporation, as opposed to the sale, of shares should pay no capital gains tax, according to the country’s Administrative Council of Tax Appeals (Conselho Administrativo de Recursos Fiscais).
-
June 13, 2013
Switzerland’s upper house of Parliament approved a draft proposal to let the country’s banks forgo secrecy laws to appease the US yesterday, but some taxpayers may fear that tax information exchange agreements (TIEA) will see information transferred beyond the US.
-
June 13, 2013
UK telecommunications group Vodafone has defended its position in its dispute with the Indian tax authorities and in the much scrutinised settlement with HM Revenue & Customs (HMRC) in 2010 in its sustainability report 2012/13. The report also includes an overview of the total tax contribution of the group on a country-by-country basis for the first time.
-
June 06, 2013
Multinationals in India must maintain caution in their transfer pricing reporting of transactions involving investment into foreign subsidiaries even though the Hyderabad Income Tax Appellate Tribunal (ITAT) said transfer pricing rules do not apply in these circumstances.
-
June 06, 2013
If Vodafone accepts the Indian cabinet’s offer to enter a conciliation process under the Indian Arbitration and Conciliation Act to try and resolve its longstanding tax dispute, the Indian government may have to open up such a resolution mechanism to other multinationals.
-
June 06, 2013
HM Revenue & Customs’ (HMRC) head of dispute resolution, Val Hennelly, and Malcolm Twyman, an accredited mediator at HMRC, explained when taxpayers should consider using alternative dispute resolution (ADR) to resolve large and complex tax cases at an event hosted by accountancy firm BDO in London last night.
-
May 30, 2013
In the last of his four-part series for International Tax Review, Donald Bowman QC, former Chief Justice of the Tax Court of Canada, now counsel to Dentons’ national tax group, examines the increased use of expert testimony in disputes involving R&D tax credits.
-
May 30, 2013
Energy groups with petroleum projects in Australia need to change the way they document expenditure to ensure they can successfully substantiate exploration expense deductions, following a judgment published by the country’s Administrative Appeals Tribunal (AAT) yesterday.
-
May 30, 2013
India’s tax authority has filed a special leave petition with the Supreme Court attempting to overturn the High Court’s ruling in the Sanofi case, and is also asking the court to reassess the principles set down in its Vodafone judgment.
-
May 30, 2013
Sonya Manzor, of William Fry, explains how Ryanair’s recent High Court defeat highlights that an intention to provide management services is not sufficient to enable taxpayers to claim a VAT refund.
-
May 28, 2013
In 2001, Provisional Measure No. 2,158 was published in Brazil which allowed the Brazilian tax authorities to tax the profits of controlled and affiliated companies established in other countries, even if they had not been distributed to the Brazilian parent.
-
May 23, 2013
US multinationals should see their transaction costs reduced when investing in foreign jurisdictions following the Supreme Court’s judgment in favour of energy company PPL.
-
May 22, 2013
In the third of his four-part series for International Tax Review, Donald Bowman QC, former Chief Justice of the Tax Court of Canada, now counsel to Dentons’ national tax group, discusses the increased use of expert testimony in disputes involving tax treaty interpretation.
-
May 22, 2013
The UK Supreme Court dismissed HM Revenue & Customs’ (HMRC) appeal in the first part of its judgment in the Marks & Spencer (M&S) dispute. The court’s answer means taxpayers will have more flexibility when claiming cross-border group relief.
-
May 20, 2013
International Tax Review has produced tax disputes reference guides for 26 countries. The guides look at how multinationals can avoid and manage tax disputes in each jurisdiction as well as offering insight about the future litigation strategies of individual tax authorities.
-
May 16, 2013
The Supreme Court of the Netherlands has delivered a judgment which allows a Dutch taxpayer to deduct losses incurred on a related party loan, creating an exception to the shareholder loan doctrine set out by the court in November 2011.
-
May 16, 2013
Germany’s intent to incorporate mandatory binding arbitration provisions in current and future double taxation agreements (DTA) should allow taxpayers to eliminate the risk of double taxation in cross-border cases and help them exert pressure on tax authorities to reduce the length of disputes.
-
May 16, 2013
Taxpayers with a permanent establishment (PE) in India can use a profit attribution method described in the Delhi Income Tax Appellate Tribunal’s (ITAT) Convergys judgment to guide their behaviour in what remains an area of legal uncertainty in India.
-
May 15, 2013
Venture Capital Trusts (VTC) and Investment Trust Companies (ITC) risk losing out on reclaiming VAT mistakenly paid to HM Revenue & Customs (HMRC) if they do not act now.
-
May 14, 2013
There is a new federal programme which promises a fresh landscape for tax benefits in Brazil.
-
May 13, 2013
In the second of his four-part series for International Tax Review, Donald Bowman QC, former Chief Justice of the Tax Court of Canada, now counsel to Dentons’ national tax group, examines the use of expert witnesses in transfer pricing cases and in giving valuation opinions.
-
May 10, 2013
In a ruling handed down May 6, 2013, Canada's Federal Court of Appeal ordered that portions of a Crown pleading be struck out on Monday for suggesting that a tax deduction may be disallowed on the basis that the conduct of the taxpayer in incurring the expense was egregious or repulsive.
-
May 09, 2013
The European Commission is renewing its inquiry into tax benefits provided to Electricité de France (EDF) by the French government despite the European Court of Justice (ECJ) finding in the taxpayer’s favour last June.
-
May 09, 2013
The Finnish government is asking India to enter a mutual agreement procedure (MAP) under the tax treaty between the two countries in an attempt to negotiate a settlement over Nokia's controversial INR 2,000-crore ($368.8 million) tax bill.
-
May 09, 2013
Donald Bowman QC, former Chief Justice of the Tax Court of Canada, now counsel to Dentons' national tax group, discusses how taxpayers and their counsel can most effectively use expert witnesses in a Tax Court trial.