Robert Waterson, senior associate at Hage Aaronson, explains why the further judgment in Investment Trust Companies (In Liquidation) v HMRC (ITC) is good news for taxpayers who suffered unlawfully levied VAT but had no direct right of action against HM Revenue & Customs (HMRC) under section 80 of the Value Added Tax Act 1994 (VATA).
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Experts reportedly discussed extending the safe harbour to 2027 to give countries more time to legislate; in other news, Baker McKenzie and Greenberg Traurig made senior tax hires
Hany Elnaggar examines how Gulf Cooperation Council countries are internalising transfer pricing norms within evolving fiscal systems shaped by both Islamic and international influences
Where a TP study of comparables produces an arm’s-length range, and the taxpayer’s filed position is outside that range, HMRC will adjust to the median by default
Despite legislative gridlock, international investors should be wary of legal precedents set by recent court rulings, which could substantially alter the Spanish tax environment