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  • Luxembourg’s plan for AIFMD puts tax in the spotlight

    Laetitia Borucki of Bonn Steichen & Partners believes fund managers should review the potential tax impacts relating to residency, VAT and carried interest that are included in Luxembourg’s draft law to implement the EU Alternative Investment Fund Managers Directive. The creation of a new type of partnership is also to be considered.

  • Transparency: A little information is a dangerous thing

    As was recently acknowledged by Monica Bhatia, who heads the OECD’s Global Forum on Transparency and Exchange of Information, “we are seeing a rise in tax transparency, and it’s only going in one direction: more transparency”. Mark Friezer, partner at Clayton Utz in Sydney, explores the latest disclosure requirements being imposed on taxpayers in Australia.

  • The world is changing: The gradual evolution of tax planning

    The world of tax planning is changing, bringing new risks and challenges for taxpayers. The change may be gradual, but companies should not ignore how significant it is.

  • Unitary taxation with combined reporting: The TP solution?

    The OECD’s Base Erosion and Profit Shifting (BEPS) project issued a report in February 2013, which confirmed that the present international tax rules are not effective: “There is increased segregation between the location where actual business activities take place and the location where profits are reported for tax purposes.” David Spencer, formerly a senior adviser and head of transfer pricing for the Tax Justice Network, explores the viability of unitary taxation and questions whether it is a realistic option, considering the way international commerce operates.

  • The rise of carbon pricing in the BRICS

    Carbon pricing is increasingly becoming part of the BRICS’ strategy to tackle climate change. Emma Powell examines how these countries are implementing it and what effect it will have on businesses.

  • EU VAT reform could go much further

    Stuart Adam and David Phillips of the UK Institute for Fiscal Studies argue that the EU’s VAT reform plans could go much further in looking to abolish exemptions and reduced rates.

  • Portuguese VAT anti-abuse rules

    The increasing sophistication of transactions performed between taxpayers has raised concerns among legislators about the recurrent manipulation of the terms and conditions of such transactions as a way of reducing the tax impacts, thus distorting the objectives of the tax systems. Rui Guedes Henriques, Tiago Almeida Veloso and Ana Filipa Janine of Baker Tilly look at the VAT anti-abuse rules introduced in the 2012 budget to address these concerns.

  • Why taxpayers should not withdraw claims after Wheels

    Nick Skerrett and Matthew Rees, of PwC, explain why the European Court of Justice’s (ECJ) ruling in the case of Wheels Common Investment Fund Trustees v HMRC means the question of VAT on investment management fees in the context of pensions remains unresolved and why taxpayers should not withdraw their claims just yet.

  • International mismatches: BEPS and a Danish example

    Jens Wittendorf, of Deloitte Denmark, examines a recent dispute in the National Tax Tribunal (NTT) which highlights how unilateral anti-hybrid legislation can have the unintended consequence of eroding the domestic tax base.

News Analysis


Tax Relief

  • Tax Relief

    A monthly commentary on the notable facts, figures and goings-on in the tax world.

International Correspondents

International Correspondents