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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

Canadian Prime Minister Mark Carney and US President Donald Trump have agreed that the countries will look to conclude a deal by July 21, 2025
The firm’s lack of transparency regarding its tax leaks scandal should see the ban extended beyond June 30, senators Deborah O’Neill and Barbara Pocock tell ITR
Despite posing significant administrative hurdles, digital services taxes remain ‘the best way forward’ for emerging economies, says Neil Kelley, COO of Ascoria
A ‘joint understanding’ among G7 countries that ‘defends American interests’ is set to be announced, Scott Bessent claimed
The ‘big four’ firm’s inaugural annual report unveiled a sharp drop in profits for 2024; in other news, Baker McKenzie and Perkins Coie expanded their US tax benches
Representatives from the two countries focused on TP as they met this week to evaluate progress under a previously signed agreement – it is understood
The UK accountancy firm’s transfer pricing lead tells ITR about his expat lifestyle, taking risks, and what makes tax cool
Dolphin Drilling intends to discuss the final liability amount and manner of settlement with HM Revenue and Customs
Winning the case against the 20% VAT imposition was always going to be an uphill challenge for the claimants, UK tax advisers argue
A ‘paradigm shift’ in Chile’s tax enforcement requires compliance architecture built on proactive governance, strategic documentation and active monitoring of judicial developments
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