When the UK Supreme Court ruled in favour of HM Revenue and Customs (HMRC) in the Tower MCashback decision in May concerning capital allowances, many tax practitioners lamented what the Court seemed to be saying about the tax avoidance arguments that HMRC may advance during a hearing. The decision comes at a time when HMRC is entering into more enquiries and disputes with corporate taxpayers. Erin Kelechava investigates whether the case is yet another sign of a new era defined by more contentious relationships between Revenue and taxpayers.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The OECD’s project was up for debate as Matt Williams spoke to ITR following BDO’s tax strategist survey, which uncovered increased complexity and costs among multinationals
Jean-Michel Henry and Mona El-Begawi of Deloitte Luxembourg examine the complexities created by timing differences in Luxembourg, EU, and OECD tax regimes
Samuel Fernandes de Almeida of MFA Legal & Tech assesses whether Portugal’s 7.5% surcharge on non-residents aligns with the EU’s free movement of capital principle and passes the proportionality test
Senior McCarthy Tétrault tax practitioners highlight significant updates and implications for multinationals as Canada’s transfer pricing rules become more closely aligned with OECD guidance