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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

The OECD profile signals Brazil is no longer a jurisdiction where TP can be treated as a mechanical compliance exercise, one expert suggests, though another highlights “significant concerns”
Libya’s often-overlooked stamp duty can halt payments and freeze contracts, making this quiet tax a decisive hurdle for foreign investors to clear, writes Salaheddin El Busefi
Eugena Cerny shares hard-earned lessons from tax automation projects and explains how to navigate internal roadblocks and miscommunications
The Clifford Chance and Hyatt cases collectively confirm a fundamental principle of international tax law: permanent establishment is a concept based on physical and territorial presence
Australian government minister Andrew Leigh reflects on the fallout of the scandal three years on and looks ahead to regulatory changes
The US president’s threats expose how one superpower can subjugate other countries using tariffs as an economic weapon
The US president has softened his stance on tariffs over Greenland; in other news, a partner from Osborne Clarke has won a High Court appeal against the Solicitors Regulation Authority
Emmanuel Manda tells ITR about early morning boxing, working on Zambia’s only refinery, and what makes tax cool
Hany Elnaggar examines how AI is reshaping tax administration across the Gulf Cooperation Council, transforming the taxpayer experience from periodic reporting to continuous compliance
The APA resolution signals opportunities for multinationals and will pacify investor concerns, local experts told ITR
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