The IRS experiences a significant setback in its efforts to combat so-called corporate tax shelters and alleged
abusive transactions, unexpectedly concedes the inclusion of stock options in cost sharing pool in Seagate, and has acquiesced on the UK petroleum revenue tax in Exxon v Commissioner. By Hal Hicks, David Benson and Margaret O’Connor, Washington DC
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While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems