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  • Retrospective amendments

    The last 12 months have seen a surge in the use of retrospective amendments by governments around the world, all aimed at recouping extra revenue from taxpayers. Matthew Gilleard assesses the issues thrown up by lawmakers going back in time, and whether this worrying trend for taxpayers is set to continue.


  • VAT and intermediation in real estate company shares

    Cédric Tussiot and Joachim Bailly look at intermediation in the sale of shares of real estate companies in Luxembourg and whether VAT should be applied, based on the recent European Court of Justice case for broker firm DTZ Zadelhoff vof.

  • Michael Meacher speaks for the voiceless on tax justice

    Michael Meacher, former UK Minister of State for the Environment under Tony Blair, stepped up the fight against tax avoidance in the House of Commons last month with his general anti-tax avoidance principle (GATAP) Bill. Salman Shaheen talks to the Labour Member of Parliament about his campaign and how it is gaining momentum.

  • How Brazil’s approach to large taxpayers is evolving

    Multinationals are clambering over one another to try to establish themselves in Brazil, confident of the rich rewards such investment could reap while the country continues to harbour one of the world’s fastest growing economies. But how is Brazil’s tax administration coping with this changing business landscape? In an exclusive interview, Joe Dalton speaks with Monica Calijuri, Commissioner of the Federal Revenue of Brazil’s Large Business Office in São Paulo, to find out what part the tax authorities are playing in bringing more investment to Brazil.

  • Investing in the EU through an SPV

    To route their investments in a tax efficient manner, investors in the EU often use special purpose vehicles (SPV) incorporated in a third-party jurisdiction. The preferred jurisdictions are generally Luxembourg, the Netherlands, and, to a lesser extent, the UK or Switzerland (which benefits from certain EU directive rules under EU-Swiss agreements). Antoine Vergnat of McDermott Will & Emery in Paris provides a practical description of the main substance-related requirements that SPVs must satisfy to benefit from exemptions or reductions of withholding taxes on portfolio incomes derived from EU operating companies (which assets are not predominantly made up of real estate assets).

  • Foreign affiliate dumping proposals change the landscape

    The Canadian government looks set to implement new foreign affiliate dumping rules, but the proposals go further than expected and, if enacted without alterations, would impose severe limitations on Canadian taxpayers, explain Ian Crosbie and Raj Juneja, of Davies Ward Phillips & Vineberg LLP.

  • Tax loss carryovers: The hardening of the French regime

    Until last year, France used to be a tax-friendly country for loss making enterprises. Sonia Bonnabry of LEXCOM explores why this is not necessarily the case anymore, following the tightening of French rules in the second Amended Finance Bill for 2012.

  • Management services in transfer pricing: The battleground

    The Indian transfer pricing regulations are expected to provide a more robust framework for taxpayers and the revenue authorities alike to demonstrate the arm’s-length character of their related-party transactions. However, Amit Agarwal of Ernst & Young argues that the wide discretion conferred on the revenue authorities in the interpretation and implementation of these regulations has spawned a cesspool of tax controversies leading to substantial tax adjustments. It is reported that in the latest round of transfer pricing audits the cumulative value of these adjustments was $8.9 billion.

  • What you need to know about the OECD’s recent TP reports

    The OECD released a number of reports relating to transfer pricing recently. The draft on intangible assets was released ahead of schedule in June, but the organisation has also produced a draft on safe harbours and memorandums of understanding and another on timing issues. Sophie Ashley considers the practical implications of these reports.

  • The future of Israeli indirect taxation

    Israel has introduced a number of indirect tax changes recently. Tal Hamdi of Herzog Fox & Neeman looks at where they are going.

  • Bad debt VAT relief claims: all about the money

    David Jamieson of Baker & McKenzie looks at whether the door is open again for further VAT rebates after the GMAC/BT case.

  • Italy MAPs out future approach to dispute resolution

    Antonio Tomassini and Alessandro Martinelli, of DLA Piper, analyse a recent Italian circular which gives clarity on mutual agreement procedures (MAP) and look at how its guidelines will interact with domestic law.

  • With section 6676, it does hurt to ask

    Thomas Durham, Brian Kittle and William Schmalzl of Mayer Brown explain why section 6676, the recently enacted refund penalty that imposes a penalty on the filing of certain refund claims, is hitting taxpayers hard.

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