Canada’s Morguard ruling may not stop taxpayers putting break fees on capital account Canadian taxpayers whose business is acquiring companies may still be able to file break fees received under a pre-acquisition agreement on capital account, despite the Federal Court of Appeal’s (FCA)... By Joe Dalton November 28 2012
Hybrid security arrangement escapes GAAR in Australian High Court case Multinationals can raise capital in Australia and pay distributions to Australian resident investors out of foreign source income with imputation benefits attached, after the High Court’s ruling in a general... By Joe Dalton November 28 2012
ATO outlines position on GST after High Court’s Qantas ruling The Australian Taxation Office (ATO) says the goods and services tax (GST) treatment of a transaction will not necessarily be affected if goods or services contemplated by a contract are... By Joe Dalton November 22 2012
Indian ITAT ruling helps justify royalty payments by manufacturers to group companies A recent ruling by India’s Income Tax Appellate Tribunal (ITAT) Mumbai bench should help to justify the payment of royalty by entities undertaking contract manufacturing, toll manufacturing or fully-fledged manufacturing... By Joe Dalton November 22 2012
Indian ITAT ruling helps justify royalty payments by manufacturers to group companies A recent ruling by India’s Income Tax Appellate Tribunal (ITAT) Mumbai bench should help to justify the payment of royalty by entities undertaking contract manufacturing, toll manufacturing or fully-fledged manufacturing... By Joe Dalton November 22 2012
Hong Kong’s revenue commissioner to appeal Nice Cheer Investment ruling Hong Kong’s highest court will rule on the tax treatment of unrealised gains from trading investments after the Court of Appeal granted leave to the Inland Revenue Department (IRD) commissioner... By Joe Dalton November 21 2012
How multinationals can prepare their French subsidiaries for tax raids A worrying trend is emerging for taxpayers in France, because the tax authorities are increasingly targeting foreign multinationals with French subsidiaries in tax raids. By Joe Dalton November 15 2012
Is Alcoa’s “historic” Annual Compliance Arrangement a good move? Alcoa, the multinational aluminium producer, recently signed an Annual Compliance Arrangement (ACA) that was described by Australian Tax Commissioner Michael D’Ascenzo as “historic” because of its comprehensive nature. By Joe Dalton November 14 2012
Vodafone confident of success under BIT if Indian tax battle renewed UK telecommunications multinational Vodafone believes it will be able to make a successful claim against the Indian tax authorities if they use new retrospective legislation to demand further tax payments... By Joe Dalton November 14 2012
ECJ rules in favour of taxpayers in FII GLO case The European Court of Justice delivered its second judgment in the Franked Investment Income (FII) Group Litigation today, finding mainly in favour of the taxpayers. By Joe Dalton November 13 2012
