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  • Cover story

    For the tax world, 2013 was a year of rapid change. While not all the proposed reforms that dominated the year’s headlines will see the light of day in the next 12 months, 2014 is still set to be a year of evolution.

  • Corporate tax: The impact of BEPS and beyond

    Matthew Gilleard analyses the corporate tax trends that will dominate taxpayers’ time in 2014, discovering that while base erosion and profit shifting will certainly continue to be the buzzwords of international taxation, there will be plenty of other issues keeping tax departments busy next year.

  • The steady evolution of indirect tax reform

    With many big indirect reforms being announced in the last year, 2014 is set to be a year of continuing evolution, reports Salman Shaheen.

  • The future is bright for transfer pricing

    The next year for transfer pricing is dominated by the OECD’s base erosion and profit shifting (BEPS) work but, while this project overshadows most other pricing issues, it is not the only one on the horizon. Sophie Ashley takes a look ahead for 2014.

  • How the courts could redefine planning limits in 2014

    Joe Dalton reviews the key court cases in major jurisdictions that will impact multinationals next year, analysing the potential implications of the judgments for international tax planning.


  • India’s GAAR: Nice idea, shame about the execution

    Vijay Krishnamurthy, CFO, company secretary and legal head at SmartPlay Technologies India, looks at the recently notified general anti-avoidance rules (GAAR) in India, analysing whether certain inconsistencies remain and whether the recommendations of the specialist Parthasarathi Shome-led committee should have been adopted in full.

  • Cross-border services in tax treaties: crossing the PE border

    Developing countries often impose withholding tax on payments for certain offshore services. Companies should be aware of where in the world this occurs and the potential protection under tax treaties so they can plan accordingly, says Konstantin Korobchenko of EY and the University of Leiden.

  • Americas Tax Awards 2013

    The eighth Americas Tax Awards in New York on September 26 was the biggest ceremony to date and also saw the introduction of the new deal awards.

  • Germany’s new rules on profit allocation to insurance PEs

    Ulf Andresen and Jobst Wilmanns of PwC in Frankfurt, explain how Germany’s new profit allocation rules for insurance permanent establishments (PE) potentially discriminate against foreign insurers.

  • Test case for cross-border ruling requests is good for business

    For any business engaged in EU cross-border transactions, the European Commission’s test case for private VAT ruling requests relating to cross-border situations is a great initiative to try to bridge the gap between EU VAT law and national VAT law, argue Mark Hammond Giles and Karl-Heinz Haydl, two VAT practitioners at a multinational company.

  • VAT in the EU: the law of unintended consequences

    Peter Duchars, of SMP Partners, a Russell Bedford member firm, looks at efforts to harmonise the EU VAT system and the unexpected new challenges this may create.

  • Taxpayers hope Supreme Court treads softly in Woods

    The US Supreme Court heard the oral arguments in the Woods dispute last month, which deals with whether valuation misstatement penalties are applicable in tax shelter cases. Professor David Shakow, of the University of Pennsylvania Law School and counsel at Chamberlain, Hrdlicka, White, Williams & Aughtry, who filed an amicus brief against the government in the case, explains why taxpayers hope the court’s judgment will help clarify two controversial areas of US tax law.

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International Correspondents

International Correspondents