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Tax Disputes

Tax Disputes archive
  • Businesses report difficulties in obtaining APAs with China

    May 28, 2015

    Though China has had an advance pricing agreement (APA) programme for nearly a decade, some businesses report that obtaining APAs in China is challenging due to a lack of manpower at the State Administration of Taxation’s (SAT) transfer pricing team.

  • ECJ clarifies German case on investment fund lump-sum taxation

    May 28, 2015

    In its judgment dated May 21 2015 (Wagner-Raith) the European Court of Justice (ECJ) confirmed that the German lump-sum taxation according to section 18 paragraph 3 of the German Foreign Investment Act (GFIA), as effective until the end of 2003, is within the scope of the standstill clause of article 57, EC Treaty.

  • Nokia withdraws asset freeze request as Delhi High Court case begins

    May 28, 2015

    Nokia India’s latest dispute with the Indian tax authorities kicked off on Tuesday [May 26 2015] in the Delhi High Court.

  • India: Changing perceptions through administrative evolution

    May 27, 2015

    Ashwani Mehta, former Chief Commissioner of Income Tax at the Indian Revenue Service, who retired in February after more than 35 years at the IRS department, assesses recent developments in Indian income taxation.

  • Swiss court challenges fundamental OECD tax principle

    May 27, 2015

    The OECD has updated the commentaries on the Model Tax Convention (Commentaries) seeking to clarify the concept of beneficial ownership in tax treaties. Charles Hermann, a financial services tax partner at KPMG, explores beneficial ownership issues arising from the ‘Swiss Swap’ case.

  • Collections delayed on transfer pricing bills under India-UK DTAA

    May 25, 2015

    The Indian Ministry of Finance has issued a fresh notice preventing the collection of taxes on transfer pricing cases for Indian subsidiaries of UK resident companies undergoing a mutual agreement procedure (MAP).

  • European Tax Awards 2015 - the winners

    May 22, 2015

    The European Tax Awards 2015 were presented last night at a dinner at the Grosvenor House Hotel in London.

  • Americas Awards 2015: Entry forms are available now

    May 20, 2015

    This year's Americas Tax Awards will take place in New York on September 17. Make sure you are ready to compete.

  • Uncertainty remains around tax treatment of Brazilian current account structures

    May 20, 2015

    Current account structures enable companies in the same economic group to make cash available to each other, generating reciprocal obligations of booking the amounts corresponding to withdrawals and disbursements of cash, without one being considered a creditor or debtor of the other.

  • Jaitley orders tax authorities to stop issuing MAT bills

    May 15, 2015

    India’s Finance Minister Arun Jaitley has told the tax authorities not to send out any new bills for minimum alternate tax (MAT) to foreign portfolio investors while a committee he has created enquires into the controversy.

  • JPMorgan under investigation for tax evasion in France

    May 14, 2015

    France has launched a formal investigation into American bank JPMorgan over allegations that some of its senior managers helped French investment company Wendel to evade tax.

  • Vestager delays verdict on EC state aid investigations in to Apple, Amazon, Starbucks and Fiat

    May 13, 2015

    The European Commission (EC) will miss its June deadline to complete state aid investigations into tax rulings for Amazon, Apple, Fiat and Starbucks, competition commissioner Margrethe Vestager has announced.

  • Are too many Swiss banks using the US DoJ self-reporting programme?

    May 07, 2015

    The US Department of Justice (DoJ) self-reporting programme for Swiss banks, which was launched in 2013, offers banks the chance to bring US taxpayers’ undeclared assets into the open in return for immunity from prosecution.

  • BHP Billiton faces $432 million tax bill in Australia

    May 06, 2015

    The Australian Tax Office has challenged the transfer pricing practices of BHP Billiton, serving the country’s largest taxpayer with a A$522 million ($432 million) tax bill, based on the pricing of goods it sold to a marketing affiliate in Singapore. The company’s Singapore tax bill is also being questioned under Australia’s controlled foreign company (CFC) rules, which require a minimum payment of tax.

  • Investors challenge Indian MAT

    May 04, 2015

    Several foreign portfolio investors have banded together to challenge India's minimum alternate tax (MAT) on capital gains in a case that will have wide-reaching implications for investors who face hefty tax bills between 2009 and 2015.

  • HMRC faces legal action over LDF handling

    April 30, 2015

    UK revenue authority HM Revenue & Customs (HMRC) could face a judicial review over the way it used the Falciani list, and its Liechtenstein Disclosure Facility (LDF) tax amnesty.

  • Polish referral to ECJ could affect insurance outsourcing VAT across EU

    April 30, 2015

    Poland has referred a case to the European Court of Justice (ECJ) which could dramatically impact insurance outsourcing activity across Europe.

  • Shome leaves ministerial adviser role behind

    April 28, 2015

    Partho Shome’s 30-year career as a tax official and adviser to Indian governments and multilateral organisations may be at an end for now, but he will still take a keen interest in tax policy, as this exclusive interview with International Tax Review reveals.

  • Tax planners’ task tougher than ever

    April 28, 2015

    Failing to plan is planning to fail. We are all familiar with the phrase. But practising what one preaches in this regard has never been more important for corporate taxpayers.

  • Mirror, mirror on the wall, please show the purpose to all

    April 28, 2015

    Rishi Joshi, associate member of the Institute of Chartered Accountants of India, analyses recent controversy and litigation on the issue of indirect share transfers.

  • Vodafone back in India’s sights for more tax

    April 22, 2015

    The Indian government is attempting to promote a more taxpayer-friendly environment, but is not being helped by demands from the tax authorities for more revenue from multinational companies. Vodafone received a notice this week relating to tax assessments for 2009-2010 and 2010-2011.

  • EC launches infringement procedure against 3% dividend distribution tax, but it may not help French taxpayers

    April 21, 2015

    The European Commission (EC) has launched an infringement procedure against France concerning its 3% tax on dividend distributions by companies liable for French corporate income tax.

  • India’s ‘taxpayer-friendly regime’ short-lived as investors get MAT bills

    April 21, 2015

    A seemingly positive exemption on Indian minimum alternate tax (MAT) for foreign portfolio investors turned sour when Prime Minister Narendra Modi announced back-taxes of more than $6.4 billion on 100 foreign investors into India, with thousands more at risk. The announcement has caused some investors to decry the government’s promises of a taxpayer-friendly regime.

  • HSBC under criminal investigation in France

    April 15, 2015

    France has opened a formal criminal investigation into HSBC’s Swiss subsidiary, and will also probe the financial institution’s global holding company.

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International Tax Review Profile

RT @BMRAdvisors: @mukeshbutani shared views in the panel discussion 'Anti-abuse provisions & tax litigation' today at #TaxandConf in #Milan…

May 28 2015 12:36 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @EYnews: EY wins 9 awards at @IntlTaxReview European Awards 2015, including European #Tax Compliance & Reporting Firm of the Year

May 28 2015 12:34 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @pierremoscovici: At #G7 Meeting in #Dresden today: acting together for a more dynamic global economy and greater tax transparency @EU_C…

May 28 2015 12:32 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @EY_Tax: EY wins 9 awards at @IntlTaxReview European Awards 2015, including European #Tax Compliance & Reporting Firm of the Year

May 28 2015 10:56 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @Freshfields: Proud to be European, UK & France "Tax Firm of the Year" http://t.co/z3ax1H9kvP #ITRawards2015 @IntlTaxReview

May 27 2015 02:10 ·  reply ·  retweet ·  favourite
International Correspondents

After the Irish budget, what would make you more likely to put more substance into Ireland?