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Tax Disputes

Tax Disputes archive
  • Belgium referred to ECJ in overseas property tax dispute

    June 25, 2015

    The European Commission (EC) has referred Belgium to the European Court of Justice (ECJ) over its tax treatment of Belgian taxpayers holding property abroad.

  • French tax treatment of foreign dividends and interplay with fundamental EU freedoms

    June 23, 2015

    French corporate tax legislation stipulates that distributions of profits from a subsidiary to a French parent company are not, in principle, taxed at the parent. Excluded from this, however, is a 5% proportion, which represents the charges incurred by the French parent company in connection with its holding in the subsidiary. These charges are not to be deductible because they serve the realisation of non-taxable income by the French parent company, namely the distribution of profits from its subsidiaries.

  • Indian Income Tax Department’s Rs 20,000 crore demand disrupts Cairn merger

    June 19, 2015

    The Indian Income Tax Department (ITD) has decided to pursue a Rs 20,495 crore ($3.2 billion) tax case against Cairn India, jeopardising the company’s proposed reverse merger with parent company Vedanta, the Central Board of Direct Taxes (CBDT) has confirmed.

  • ECJ rules against UK’s reduced VAT rate for green services

    June 18, 2015

    The European Court of Justice (ECJ) has told the UK that it is in breach of the VAT Directive by offering a reduced VAT rate for the supply and installation of energy-saving measures such as solar panels and loft insulation.

  • HMRC could lose one in five staff

    June 18, 2015

    The UK revenue collection agency, HMRC, could lose more than a fifth of its staff because of government cuts, a trade union has warned ahead of the government’s comprehensive spending review.

  • EC publishes Belgium excess profit regime state aid decision; issues injunctions to other member states

    June 12, 2015

    The European Commission (EC) has published in its Official Journal a notification about its investigation into whether Belgium’s excess profit tax ruling system constitutes state aid and has ordered Estonia and Poland, along with 15 other member states, to provide more information on their tax ruling practices.

  • Discharge of the Brazilian payroll

    June 11, 2015

    One of the sources of revenue for social security is the social contribution applicable on the payroll, under the responsibility of the employer, the company and any entity similar to it.

  • UK Supreme Court: Pendragon's VAT arrangements were abusive

    June 10, 2015

    HM Revenue & Customs won its appeal in the UK Supreme Court today against a Court of Appeal decision that a VAT scheme used by Pendragon, Europe's largest car sales group, was not an abuse of law.

  • Rectification in Canada

    June 07, 2015

    Paul Stepak and Andrew Jun of Blake, Cassels & Graydon provide a summary of recent instances in which rectification law was applied in Canada.

  • US Supreme Court ruling: How wide-ranging will the Maryland-Wynne verdict be?

    June 02, 2015

    The US Supreme Court has ruled that the state of Maryland has been operating a tax system which is unconstitutional and which has led to double taxation for taxpayers because of the lack of tax credits for income earned out-of-state.

  • Ireland updates mandatory disclosure regime

    June 01, 2015

    Brian Duffy of William Fry Tax Advisors – Taxand Ireland looks at the impact changes to Ireland’s GAAR will have on the country’s mandatory disclosure regime.

  • ITR launches app!

    June 01, 2015

    The International Tax Review app is now available! International Tax Review subscribers can now download the ITR app, giving them full access to the latest ITR articles while they are on the go.

  • 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 on May 21 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.

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Jul 1 2015 10:22 ·  reply ·  retweet ·  favourite
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Fund structuring for LatAm: The Curaçao fund for mutual account http://t.co/D6zJI0QMmt #financialservicesfocus2015 #steevenszbeckers

Jul 1 2015 09:54 ·  reply ·  retweet ·  favourite
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@UKSupremeCourt says taxpayer is entitled to #tax relief on US income he brought to UK http://t.co/9ukcEu5yos #AnsonvHMRC #Delaware

Jul 1 2015 09:22 ·  reply ·  retweet ·  favourite
International Tax Review Profile

@JunckerEU @pierremoscovici to meet @EuroParl_EN #tax rulings committee on Thursday to discuss @EU_Commission corporate tax plans

Jun 30 2015 10:59 ·  reply ·  retweet ·  favourite
International Tax Review Profile

#Tax issues in the Peruvian financial system http://t.co/gQxn38oRlr #financialservicesfocus2015 @bbva #RamonEsquivesEspinoza #nonresidents

Jun 30 2015 10:54 ·  reply ·  retweet ·  favourite
International Correspondents

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