China introduces mutual agreement process China’s State Administration of Taxation (SAT) implemented a measure for taxpayers to take advantage of mutual agreement procedures (MAP) for the resolution of cross-border tax disputes this month. By Joe Dalton November 18 2013
IBM fights Indian challenge over software exports US multinational IBM is fighting a challenge from the Indian tax authorities over an exemption which it tried to claim on income generated from software exports. By Joe Dalton November 12 2013
New Zealand’s Inland Revenue sets out compliance for multinationals Multinationals in New Zealand have been told exactly what is expected of them in a new document outlining compliance requirements and the approach the Inland Revenue will take towards cross-border... By Joe Dalton November 12 2013
Why US Tax Court refused to grant Medtronic's protective order Medical technology multinational, Medtronic, could suffer after the US Tax Court denied the company's request for a protective order in its transfer pricing case. By Joe Dalton November 07 2013
Brazilian miner Vale suffers blow in CFC tax treaty case The Federal Prosecutor’s Office (MPF) in Brazil has issued an opinion against mining multinational Vale in its fight to show that the country’s controlled foreign company (CFC) rules unlawfully override... By Joe Dalton November 07 2013
China puts itself on the MAP A measure introduced by China’s State Administration of Taxation (SAT) to help taxpayers invoke the mutual agreement procedure (MAP) for the resolution of cross-border tax disputes took effect on Friday. By Joe Dalton November 06 2013
Lessons from US Tax Court's refusal to grant Medtronic's protective order Medical technology multinational, Medtronic, could suffer damaging consequences after the US Tax Court denied its request for a protective order in its transfer pricing case so it is important that... By Joe Dalton November 06 2013
How the courts could redefine planning limits in 2014 Joe Dalton reviews the key court cases in major jurisdictions that will impact multinationals next year, analysing the potential implications of the judgments for international tax planning. By Joe Dalton November 01 2013
What taxpayers should know about bringing legitimate expectation claims against HMRC The doctrine of legitimate expectation arises in UK disputes where HM Revenue & Customs (HMRC) has reversed its position on a ruling issued to a taxpayer to the detriment of... By Joe Dalton October 31 2013
Banks concerned about BEPS-driven TP rules adding to existing regulatory burden Transfer pricing specialists at Standard Chartered, Citigroup and Nomura Securities expect the OECD’s base erosion and profit shifting (BEPS) project to have a significant impact for financial institutions but worry... By Joe Dalton October 29 2013
