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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

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
Lindsay Clayton’s arrival at Baker McKenzie continues the firm’s storied pursuit of ex-US government lawyers, a strategy reinforced by robust World Tax rankings
Shared transaction semantics, governed data and reusable ERP design may prove the most significant benefits of the UK's move to Peppol
As pillar two reshapes global tax competition, the UK faces a crucial challenge: how to remain attractive to multinationals without sacrificing tax revenues
Pillar two may be raising less than expected, but professor René Matteotti says the regime is still changing multinational tax behaviour
Multinationals importing goods into Brazil may need to align TP files and customs documentation more closely as authorities gain new tools to challenge related-party transactions
The private equity-backed deal hands Grant Thornton immediate and impressive US scale, but World Tax data suggests the firm still has work to do to gain recognition
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