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Tax Disputes

Tax Disputes archive
  • IKEA Handel og Eiendom loses Supreme Court of Norway tax case

    October 26, 2016

    IKEA has lost an important tax battle that could have implications for other multinationals deducting interest on inter-company debt.

  • Modernising MAP – BEPS Action 14 to improve dispute resolution

    October 26, 2016

    Following approval by all members of the BEPS inclusive framework, the OECD publically released the substance and process for the peer review of BEPS Action 14 on October 20 2016.

  • European Commission state aid investigations: A timeline of events

    October 17, 2016

    International Tax Review looks at the European Commission's latest developments and where it all started for some of the biggest investigations on tax rulings between EU member states and MNES.

  • The top US tax controversies in 2016

    October 07, 2016

    There have been a number of significant developments in the area of US tax controversies during 2016. Fenwick & West highlight some of the top US tax cases from this year, including several large § 482 transfer pricing cases that could provide helpful insight for taxpayers who may be facing similar significant transfer pricing adjustments.

  • Americas Tax and Transfer Pricing Awards 2016

    October 03, 2016

    McDermott Will & Emery, the winner of the Americas Tax Firm of the Year, has shown the greatest strength in depth on both continents. The firm was honoured at the Americas Tax Awards in New York on September 15 2016. Deloitte were honoured as Transfer Pricing Firm of the Year.

  • Multinationals and the EC engulfed in state aid disputes

    October 03, 2016

    The European Commission’s long-awaited state aid decision on tax rulings issued by Ireland to US-multinational Apple has created a political typhoon. It has invited an unprecedented response from all involved parties, with some hailing the decision as a victory and others criticising the tax charge as excessive or even unwarranted. Anjana Haines and Amelia Schwanke report on the recent developments.

  • Apple Q&A: Kennedy condemns Commmision’s decision

    October 03, 2016

    The result of the European Commission’s investigation into Apple’s tax affairs has ruffled feathers on both sides of the Atlantic. Caroline Byrne sits down with Joe Kennedy to get a US perspective.

  • The driving force of Margrethe Vestager

    October 03, 2016

    Margrethe Vestager is known for taking items out of her friends’ shopping baskets if she feels they are making the wrong decision. The EU Competition Commissioner is not short of opinions when it comes to the world’s most powerful companies either – routinely provoking disagreements with major corporations since becoming commissioner in 2014. Lena Angvik takes a look at the lady behind the state aid investigations.

  • Brazilian taxpayers challenge the PIS and Cofins levy on financial revenues

    September 28, 2016

    Brazilian taxpayers go to court to challenge the increase of the PIS and Cofins after nearly 10 years of a zero rate being applied on financial revenues.

  • Troubled waters – global transparency and controversy in uncertain times

    September 27, 2016

    David Swenson, global leader of PwC's tax controversy and dispute resolution network, looks at how the OECD's BEPS project is changing the tax controversy and disputes landscape and the potential pitfalls that may emerge as certain jurisdictions do not commit to the multilateral initiatives.

  • Politicians and EU officials named in Bahamas leak of offshore assets

    September 22, 2016

    Officials, politicians, lawyers and a number of big players in countries worldwide have been named in a collection of 1.3 million files leaked from the Bahamas’ corporate registry.

  • Luxembourg remains in the spotlight for EC state aid investigations

    September 21, 2016

    Luxembourg’s tax treatment of another large multinational has been called into question by the European Commission as it looks at the tax rulings between the EU nation and a French company.

  • EU Parliament backs Commission’s state aid verdict against Apple

    September 16, 2016

    The battle lines have been drawn between the EU authorities and Ireland and Apple after members of the European Parliament criticised the US multinational for paying very little tax in Ireland for its European operations.

  • IKEA could be Vestager’s next tax target

    September 15, 2016

    Swedish multinational IKEA is on EU Competition Commissioner Margrethe Vestager’s radar as she looks for her next target following the state aid decision against Apple and Ireland.

  • Panama Papers to claim more victims as Denmark buys data

    September 14, 2016

    Hundreds of Danish taxpayers, both companies and individuals – and banks in particular – face tax investigations for offshore hidden assets after Denmark announced that it will pay for the information leaked in the Panama Papers scandal.

  • Apple state aid decision: What is the precedent, if any?

    September 05, 2016

    The head of tax at Mason Hayes Curran, John Gulliver, considers the key factors tax directors need to consider following the European Commission’s state aid decision against Apple and Ireland.

  • Multinationals under fire: Who will be the European Commission's next target?

    September 02, 2016

    Company tax directors are questioning whether the European Commission acted beyond its powers in fining Apple €13 billion ($14.5 billion) for accepting “illegal” state aid - and they are wondering whether they may be next in line.

  • Apple, Ireland to appeal EC ruling involving billions in ‘illegal’ tax benefits

    August 30, 2016

    Apple paid 1% or less in corporate tax dating back to 2003 in an Irish deal ruled illegal by the European Commission (EC). Rather than collect back taxes however, Ireland plans to appeal as a growing number of countries battle what they view as an overly-aggressive Commission.

  • PE risks of cross-border services to China

    August 26, 2016

    Foreign businesses offering cross-border service provisions to Chinese entities must take caution as the tax authorities are becoming more confident than ever in looking into cross-border transactions involving Chinese companies.

  • MNEs and Belgium attack EU Commission’s decision on excess profits tax rulings

    August 23, 2016

    BASF and at least four other multinationals are headed to the European Court of Justice arguing that competition commissioners acted beyond their powers in deciding that Belgium’s excess profits tax rulings constituted illegal state aid. The companies face billions of dollars in back taxes if they lose.

  • Google’s tax woes across the EU

    August 23, 2016

    Google is becoming the showcase firm for European countries trying to convince the public that it is taking action against multinational tax avoidance, but is it all for nothing?

  • Luxembourg appeals whistleblower ruling in LuxLeaks trial

    August 23, 2016

    The judgment in the LuxLeaks case, which has become central to the debate around transparency and whistleblowing, could be overturned as both parties appeal the verdict.

  • Unprecedented ruling in Brazil boosts PIS and Cofins credits for businesses

    August 19, 2016

    The Federal Administrative Court of Appeals (CARF) has issued an unprecedented ruling, by majority vote, on PIS and Cofins credits related to the acquisition of inputs for commercial companies.

  • Brexit survey: Are multinationals ready?

    August 10, 2016

    Brexit could cost the UK as much as £70 billion ($91 billion) a year if Britain walks away from membership in the EU single market, according to the latest estimates. So how are companies preparing? Take the ITR and KPMG survey and we'll provide a summary of respondents' answers.

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International Tax Review Profile

South Africa postpones carbon tax again to 2017 and says it is consulting on a #sugartax #MTBPS2016

Oct 26 2016 01:25 ·  reply ·  retweet ·  favourite
International Tax Review Profile

South Africa plans to raise an additional $3 million through tax measure over the next two years #MTBPS2016

Oct 26 2016 01:24 ·  reply ·  retweet ·  favourite
International Tax Review Profile

#HongKong has launched a #taxevasion study today that calls for views on #BEPS implementation

Oct 26 2016 01:15 ·  reply ·  retweet ·  favourite
International Tax Review Profile

India's finance ministry has today confirmed that a new revised DTA with S.Korea has effect from Sept. 12 2016

Oct 26 2016 01:14 ·  reply ·  retweet ·  favourite
International Tax Review Profile

Ukraine's finance minister said today that he intends to stop corruption as part of plans to amend the country's #tax code.

Oct 26 2016 01:12 ·  reply ·  retweet ·  favourite
International Correspondents