What you have missed on ITR Premium

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

What you have missed on ITR Premium

itrpremiumlogo2.gif

Analysis of the ECJ’s Philips ruling; opportunities in the Germany-Spain DTA; and why South Africa is unlikely to raise VAT were just three articles that appeared on ITR Premium last week.


COMPLIANCE MANAGEMENT

What the FATCA reporting models mean
The publication of the models for how FATCA could be implemented have focused minds on January 1 2013, when the phased enforcement of the legislation begins.


CORPORATE TAX

Analysing the Germany-Spain DTA
TREATY ANALYSIS: The old double taxation avoidance agreement between Germany and Spain was signed nearly half a century ago, so it made sense when on February 3 2011, the two countries met in Madrid to sign a new treaty and protocol.

Indian Prime Minister’s GAAR committee urges delay
In welcome news for investors, the committee appointed by the Indian government to assess the merits of general anti-avoidance rules (GAAR) in the country, led by Parthasarathi Shome, has recommended delaying its implementation by three years.


INDIRECT TAX

Why South Africa is unlikely to raise VAT
On the eve of the medium term budget policy statement, there have been rumours that a VAT rise may be on its way. Taxpayers should not panic, however.

Spanish and Israeli VAT hikes bite
The beginning of September marked VAT increases in Spain and Israel. While Spain’s three percentage point rise was much sharper than Israel’s one percentage point increase, both are hurting taxpayers.


TAX DISPUTES

ECJ says UK group relief rules breach EU law in Philips Electronics case
The European Court of Justice (ECJ) has decided that HMRC’s attempts to stop Philips UK claiming group tax relief on losses transferred from a domestic permanent establishment (PE) infringed EU law.

How to avoid a tax dispute in Singapore
Singapore is renowned for its multinational-friendly tax regime and for being a favourable holding company jurisdiction. However, this does not mean that disputes with the authorities cease to be a concern for taxpayers in the country.

more across site & shared bottom lb ros

More from across our site

If Trump continues to poke the world’s ‘middle powers’ with a stick, he shouldn’t be surprised when they retaliate
The Netherlands-based bank was described as an ‘exemplar of total transparency’; in other news, Kirkland & Ellis made a senior tax hire in Dallas
Zion Adeoye, a tax specialist, had been suspended from the African law firm since October over misconduct allegations
The deal establishes Ryan’s property tax presence in Scotland and expands its ability to serve clients with complex commercial property portfolios across the UK, the firm said
Trump announced he will cut tariffs after India agreed to stop buying Russian oil; in other news, more than 300 delegates gathered at the OECD to discuss VAT fraud prevention
Taxpayers should support the MAP process by sharing accurate information early on and maintaining open communication with the competent authorities, the OECD also said
The Fortune 150 energy multinational is among more than 12 companies participating in the initiative, which ‘helps tax teams put generative AI to work’
The ruling excludes vacation and business development days from service PE calculations and confirms virtual services from abroad don’t count, potentially reshaping compliance for multinationals
User-friendly digital tax filing systems, transformative AI deployment, and the continued proliferation of DSTs will define 2026, writes Ascoria’s Neil Kelley
Case workers are ‘still not great’ but are making fewer enquiries, making the right decision more often and are more open to calls, ITR has heard
Gift this article