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  • Tax transparency: What it means for you

    The argument for tax transparency has never been stronger and legislation is on its way. In a special issue of International Tax Review, we lay bare country-by-country reporting, information exchange, corporate social responsibility and exposure to risk to find out what transparency means for you. Plus an interview with the OECD’s Monica Bhatia.

  • The tide turns towards country-by-country reporting

    Once a fringe idea for a new accounting standard, country-by-country reporting now fits the mood of a public eager to lift the lid on corporate secrecy and is fast gaining credence with policy makers and regulators. Salman Shaheen finds out what it is, what it means for taxpayers and why the tax justice movement believes it is the panacea for tax evasion and secrecy.

  • How the OECD is promoting tax transparency

    Monica Bhatia is the head of the secretariat of the Global Forum on Transparency and Exchange of Information for Tax Purposes at the OECD. Having worked as a tax administrator and policy maker in an emerging economy, Bhatia understands the different requirements developing countries have when it comes to transparency in tax administration and is able to translate this into practical advice for the Global Forum’s members. She talks to Sophie Ashley about the work the forum is doing to promote tax transparency and exchange of information in a rapidly changing environment.

  • Automatic information exchange – a new global standard?

    The exchange of taxpayers’ information between revenue authorities has come a long way in the past decade. The idea that more than 100 countries would have signed up to information exchange on request agreements seemed fanciful even three years ago. But now another, more comprehensive exchange model is coming to the fore. Joe Dalton looks at the rise of automatic information exchange and what it will mean for taxpayers.

  • Knowing when to be transparent in a tax dispute

    Officials claim that increased transparency in tax disputes reduces exposure to long and costly battles. But disclosing sensitive information to revenue-hungry officials can be detrimental to a business’s bottom line. Jack Grocott speaks to advisers from across the world to discover when is the best time to be transparent in a dispute.

  • The rise of transparency and corporate social responsibility

    Bob Diamond was forced out of his role as chief executive of Barclays in the wake of a series of banking scandals including the deceptive altering of the London interbank offered rate (Libor interest rate). In the age of scandals and public enquiries, the desire to know more about companies’ activities, including their tax policies and compliance, is increasing from a variety of perspectives, explains Matthew Gilleard.


  • New York unleashes new tax enforcement tool

    David Koenigsberg, of Menz Bonner Komar & Koenigsberg, analyses a landmark US tax case and explains why companies must now change their approach towards whistleblowers.

  • New rules complicate Germany anti-treaty shopping law

    Germany’s anti-treaty shopping rules are among the most stringent in the world, explain Markus Schümmer and Markus Buchner of Ernst & Young. This was true for the rules that applied up to 2011, and it is still the case for the revised rules that apply from 2012 onward.

  • Guidance published for Irish securitisation companies

    Irish section 110 finance companies now commonly feature in international finance structures. Over the years their use has expanded from being the issuing vehicle in more traditional securitisation and repackaging type transactions, to a broader range of applications, such as being the issuers of Islamic finance instruments, distressed debt acquiring companies, the underlying vehicle for US life settlement funds, and, more recently as aircraft leasing companies. James Somerville of A&L Goodbody explores this trend in light of recent guidance.

  • New Swedish limitation of interest deductions

    On June 8 2012, the Swedish government proposed new legislation which will entail further restrictions on the deductibility of interest expenses on inter-company loans. Peter Utterström of Delphi presents the main features of the legislation, how it has been received, and necessary actions to take if the bill is adopted.

  • UK tax benefits of investment in infrastructure

    With the UK facing constraints in attracting capital for infrastructure projects, Margaret Stephens and Mikko Saressalo of KPMG explain why the government is turning to tax to encourage more investment in this sector.

  • PEs: Australian Treasury having second thoughts

    The Australian Treasury is working through its guidance on permanent establishments. Paul Balkus and Melissa Heath of Ernst & Young discuss the background, issues and expected Treasury approach in relation to the third tranche of the re-write dealing with the attribution rules to PEs.

  • Location saving on contract R&D arrangements

    Location saving is a hot issue in developing countries. Yin Chao, who speacialises in transfer pricing at Siemens in China, and Yin Shuping, who is an associate professor at Guangdong Polytechnique Normal University, explain China’s perspective on the transfer pricing aspects of location saving on contract R&D.

  • iXBRL Mandatory eFiling in the UK

    Steve Jeffels, head of Global Customer Segments for the Tax & Accounting business of Thomson Reuters, explains why there is no time like the present to prepare for iXBRL compliance.

  • How a mechanism to aid free circulation distorted EU market

    Richard Allen, co-founder of Retailers Against VAT Avoidance Schemes (RAVAS) and former head of Delerium Records, looks at how Low Value Consignment Relief (LVCR) has undermined the single market.

  • What the future holds for Spanish VAT

    Javier Martín Martín and Diana Garrido Hernando of Ernst & Young look at indirect tax as a way out of Spain’s dire economic situation.

  • Discrimination is not justified with investment funds

    In May the European Court of Justice (ECJ) found that French tax legislation is contrary to EU law when it taxes nationally-sourced dividends paid to certain investment funds which are resident in another state. Nadine Gelli, Eduardo Gracia and Manuel Paz of Ashurst explain why this break-through decision opens the door to a significant number of claims for full refunds to be filed by both EU and non-EU investment funds in France and all across Europe.

  • Recent challenges for inbound PE structures in Germany

    Stephan Eilers and Alexander Schwahn of Freshfields Bruckhaus Deringer provide a brief overview of a classic structure for a private equity investment in Germany, and they critically analyse the efforts of both the tax authorities and the legislature to place restrictions on debt push-down structures.

News Analysis


Tax Relief

  • Tax Relief

    A monthly commentary on the notable facts, figures and goings-on in the tax world. Suitable items should be sent to

International Correspondents

International Correspondents