Asian taxpayers get ready for BEPS reforms Taxpayers at International Tax Review’s Global Transfer Pricing Forum 2013 said they are already taking steps to ready themselves for the implementation of new tax rules and revenue authority approaches... By Joe Dalton October 23 2013
Indian taxpayers must learn not to fear site visits in APA process Taxpayers at International Tax Review’s Global Transfer Pricing Forum in Singapore reviewed the pros and cons of India’s new advance pricing agreement programme (APA), raising some concern over one of... By Joe Dalton October 23 2013
US tax reform: The potential implications for Europe US corporate tax reform could be good news for European multinationals if it forces other OECD countries to drive their own rates down yet further, according to a panel at... By Joe Dalton October 18 2013
ECJ’s ruling against Portuguese thin cap rules opens door for refunds Portuguese taxpayers could be entitled to tax refunds if they were denied interest deductions in relation to loans from non-EU entities, a European Court of Justice (ECJ) ruling has said. By Joe Dalton October 17 2013
Cairn victory in Delhi High Court lets foreign investors claim lower tax rate Energy multinational Cairn’s Delhi High Court win gives certainty for non-residents claiming the concessional tax rate of 10% on long-term capital gains arising on the disposal of listed securities in... By Joe Dalton October 17 2013
Saint-Amans adamant OECD will deliver on BEPS in two years as Commission lends cautious... Pascal Saint-Amans, the OECD’s director for tax policy, today affirmed the base erosion and profit shifting (BEPS) action plan will be completed in two years, while European Commission tax head... By Joe Dalton October 17 2013
Santander’s shock win in STARS case threatens IRS’ sham transaction argument Spanish banking group Santander’s surprising victory on summary judgment before the District Court of Massachusetts could undermine the government’s central argument in fighting the structured trust advantaged repackaged securities (STARS)... By Joe Dalton October 10 2013
Gimle’s ECJ win prevents Belgium turning exempted capital gains into taxable profits The European Court of Justice’s (ECJ) decision to disallow the Belgian tax authorities’ attempt to turn exempt capital gains into taxable profits in the Gimle case gives taxpayers certainty on... By Joe Dalton October 10 2013
Brazilian government approves amnesty for taxpayers in CFC cases Brazilian taxpayers involved in disputes centred on the country’s controlled foreign company (CFC) rules have been offered an amnesty if they withdraw their appeals. Law no. By Joe Dalton October 10 2013
Canadian Supreme Court denies Envision’s tax strategy for merger The Supreme Court of Canada has denied Envision Credit Union’s (Envision) strategy for avoiding tax upon amalgamation in a ruling which could have broader implications for the tax treatment of... By Joe Dalton October 04 2013
