Taxpayers should use ITAT’s Convergys ruling when attributing profit to Indian PEs Taxpayers with a permanent establishment (PE) in India can use a profit attribution method described in the Delhi Income Tax Appellate Tribunal’s (ITAT) Convergys judgment to guide their behaviour in... By Joe Dalton May 16 2013
Trusts must file protective VAT reclaims against HMRC by next month Venture Capital Trusts (VTC) and Investment Trust Companies (ITC) risk losing out on reclaiming VAT mistakenly paid to HM Revenue & Customs (HMRC) if they do not act now. By Joe Dalton May 15 2013
How taxpayers should respond to Brazilian Supreme Court’s CFC ruling Brazilian taxpayers are left with several options following the Supreme Federal Court’s (STF) judgment on the constitutionality of the controlled foreign company (CFC) rules last month, advisers say. By Joe Dalton May 09 2013
Finland files MAP application with India over Nokia dispute The Finnish government is asking India to enter a mutual agreement procedure (MAP) under the tax treaty between the two countries in an attempt to negotiate a settlement over Nokia's... By Joe Dalton May 09 2013
European Commission’s second EDF challenge shows state aid arrangements are still on it... The European Commission is renewing its inquiry into tax benefits provided to Electricité de France (EDF) by the French government despite the European Court of Justice (ECJ) finding in the... By Joe Dalton May 09 2013
Why the ECJ’s ruling on Spanish exit tax creates uncertainty for multinationals The European Court of Justice’s (ECJ) decision that Spanish companies transferring assets to another EU member state can defer exit tax payment was unsurprising given the court’s rulings in National... By Joe Dalton May 02 2013
Resource Capital ruling helps taxpayers with TARP valuations but ATO approach remains w... Foreign investors were given helpful guidance on how to value assets for capital gains tax purposes by the Federal Court of Australia’s ruling in favour of Resource Capital Fund III... By Joe Dalton May 02 2013
WHA loses UK Supreme Court VAT appeal The UK Supreme Court unanimously dismissed motor breakdown insurance provider WHA’s appeal over the recovery of VAT on car repair services this morning, agreeing with an earlier decision by the... By Joe Dalton May 01 2013
Brazil’s Supreme Court judgment in CFC case brings good and bad news for Vale The Supreme Federal Court (STF) of Brazil resumed its judgment in the case set to decide the constitutionality of the country’s controlled foreign company (CFC) rules yesterday and confirmed an... By Joe Dalton April 11 2013
ECJ ruling on holding companies joining VAT groups confirms BAA solution The European Court of Justice (ECJ) yesterday ruled that non-taxable entities such as holding companies are permitted to join VAT groups, dismissing an action brought by the European Commission against... By Joe Dalton April 10 2013
