Liberty Media pays $136 million to settle IRS dispute Liberty Media Corporation, the US media conglomerate, has announced that it has paid $136 million to settle its tax dispute with the IRS. By Jack Grocott December 20 2011
HMRC releases TP stats for the first time HMRC in the UK has released for the first time extensive statistics about its transfer pricing enquiries, advance pricing agreements (APAs), and mutual agreement procedure (MAP). By Jack Grocott December 20 2011
Western Union signs deal with IRS Western Union has announced that it has reached an agreement with the US IRS over the transfer pricing aspects of its restructuring of international operations in 2003. By Jack Grocott December 19 2011
Vodafone’s India SC ruling delayed to next year The decision of the Indian Supreme Court in the Vodafone case has been delayed until the New Year. By Jack Grocott December 13 2011
How Europe plans to attack private equity The private equity sector’s heavy reliance on leverage to structure portfolio acquisitions and maintain low effective tax rates is under attack in Europe. By Jack Grocott December 12 2011
Alesco suffers NZ optional convertible notes blow The New Zealand Inland Revenue Department (IRD) today won a landmark tax avoidance test case on the use of optional convertible notes (OCNs). By Jack Grocott December 12 2011
Why Dell needed to fight its PE battle in Norway Dell’s long-running battle with the Norwegian tax authorities over the issue of permanent establishment came to an end on Friday with a win for the company. By Jack Grocott December 08 2011
What India must overcome before IFRS can be implemented India has too many obstacles to overcome before it can apply IFRS, warn advisers who predict its implementation is still 18 months away. By Jack Grocott December 07 2011
Dell wins final Norwegian PE battle Norway’s Supreme Court has ruled that Dell Products, a Norwegian commissionaire company, does not constitute a sales agency permanent establishment (PE) in Norway. By Jack Grocott December 05 2011
HMRC’s general counsel explains how to improve ADR The UK’s alternative dispute resolution (ADR) pilot scheme is working but still has a number of problems to iron out before it can be fully implemented, says HMRC’s general counsel. By Jack Grocott December 01 2011