Copying and distributing are prohibited without permission of the publisher

Latest Issue

Magazine archive
  • Unlocking MAP disputes: Is mediation the key?

    Item 14 of the OECD's Action Plan on base erosion and profit shifting (BEPS) aims to devise solutions to obstacles preventing countries from resolving cross-border disputes under the mutual agreement procedure (MAP). Joe Dalton investigates whether introducing mediation techniques to the MAP process is a viable solution.


  • International tax transparency: Past, present and future

    Harm Oortwijn, director of international tax and reporting at Paramount Pictures, and owner/director of EA Tax Services BV, looks at the background and present trends regarding international tax transparency, exploring the objectives of key parties and examining the most likely outcomes.

  • Mexico: closer scrutiny of international taxpayers coming

    Oscar Molina, of the Mexican tax authorities, tells Ralph Cunningham he is prepared to challenge structures that do not keep sufficient profit in his country.

  • Seven reasons to choose a boutique tax recruitment agency

    When choosing a specialist recruitment agency, the size of the company can have a significant impact on how far that agency can be trusted to deliver the work, says Izabela Hollander-Bolton of IBH Executive

  • Indirect tax reform continues for emerging economies

    As China, India and Brazil are rapidly emerging onto the world stage, the three countries are looking to large-scale indirect tax reform. Salman Shaheen looks at how these plans are coming along and why they are important to economies opening themselves to investment.

  • TP arbitration for developing countries: Benefits and burdens

    The issue of the benefits or otherwise for developing countries of arbitration in tax matters has recently become more pressing. Michael Lennard, chief of the International Tax Cooperation section of the UN speaks in a personal capacity about some of the issues that may shape transfer pricing arbitration clauses and how they operate in future for taxpayers and their advisers.

  • Foreign employee secondments and the PE issue

    Companies often second their employees to other firms in their group abroad but this can create a permanent establishment (PE) risk; something that can take up an unreasonable amount of time for a tax director if not handled properly. Sophie Ashley speaks to taxpayers and their advisers about how best to manage the situation to avoid creating a PE.

  • Legitimate uses of LVCR

    In part two of a two-part series, Richard Allen of Retailers Against VAT Avoidance Schemes (RAVAS) looks at what could be considered a legitimate use of low value consignment relief (LVCR) in contrast to the abusive practices that have put onshore retailers like him out of business.

  • VAT in software transactions: The end of effective use

    Mirna Screpante of the Max-Planck Society Institute for Tax Law and Public Finance looks at the case for replacing the effective use criterion for VAT on software transactions in Argentina.

  • Brazilian taxpayers reveal complaints and desires

    The tax landscape in Brazil is notoriously difficult to navigate. Whether it is the number of tax obligations that must be met, the number of tax returns that must be filed, or the commonplace deviance from international norms, corporate taxpayers have a lot to contend with. The manner in which tax authorities interact with taxpayers is therefore important in either facilitating or further hindering taxpayers in their efforts to comply. Matthew Gilleard talks to taxpayers from various industries to assess their existing relationships with the tax authorities and hear their ideas for how these can be improved.

  • Multilateral cooperative compliance: The next step?

    Machiel Lambooij, of Freshfields Bruckhaus Deringer, and chair of IFA's subcommittee on enhanced relationships, discusses the potential application of cooperative compliance arrangements in cross-border situations, initially on a bilateral basis and perhaps ultimately on a multilateral basis.

  • Advocate General opinion in FII GLO encourages claimants

    The Franked Investment Income Group Litigation (FII GLO) concerning claimants' rights to recover overcharged tax from HM Revenue & Customs (HMRC) has been batted back and forth between the UK courts and the European Court of Justice (ECJ) since 2006. Philippe Freund, of Joseph Hage Aaronson, explains why an Advocate General's opinion on the third reference to the ECJ has given taxpayers cause to be optimistic.

News Analysis


  • Calling time on VAT rises

    Thousands of pubs and restaurants, which have struggled since the UK government hiked VAT to 20% in January 2011, dropped their prices by 7.5% for one day last month to show the benefits of a VAT cut.

Tax Relief

  • Tax Relief

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

International Correspondents

International Correspondents