In a ruling handed down May 6, 2013, Canada's Federal Court of Appeal ordered that portions of a Crown pleading be struck out on Monday for suggesting that a tax deduction may be disallowed on the basis that the conduct of the taxpayer in incurring the expense was egregious or repulsive.
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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