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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 UK has confirmed its approach to the OECD’s side-by-side deal, but US-parented groups may find pillar two compliance remains far from straightforward
Fragmented pillar two taxation and increased use of AI by tax authorities have left clients fearful of heightened disputes exposure
Grant Thornton Advisors’ latest acquisition has produced the fifth-largest US advisory firm by revenue, but there’s still a clear gulf between it and the big four
Crowe joins Grant Thornton, WTS and Ryan in attracting PE investment, suggesting that dealmakers remain bullish on the tax advisory sector
HMRC expects advisers to meet ever-higher compliance criteria. After 24 consecutive qualified audit opinions, many will ask whether HMRC should hold itself to the same standards
The purchase of Marosa represents the second major tax tech consolidation this week, raising questions of a broader industry trend
Peru’s approach to TP is increasingly at odds with OECD-style profitability policies, exposing multinational groups to asymmetric tax adjustments
Hany Elnaggar examines how the region's legacy economic substance regimes and the OECD's pillar two framework are converging on the same underlying test
The deals for TP Accurate and Intra Pricing Solutions will enhance Alphatax’s ability to support clients with the full TP lifecycle, the tax tech provider claimed
The DS Advocates partner discusses career reinvention, tax disputes and why advisory and litigation experience should complement one another
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