Alesco’s appeal to test application of New Zealand’s GAAR New Zealand taxpayers should be watching Alesco’s Court of Appeal case with bated breath, as the outcome could give a big indication of the extent to which the country’s general... By Joe Dalton October 11 2012
ITAT decides eBay’s Indian websites are not permanent establishments eBay International has won its case before Mumbai’s Income Tax Appellate Tribunal (ITAT) which means two of its Indian subsidiaries will not be classed as permanent establishments (PEs) for tax... By Joe Dalton October 11 2012
India’s ITAT restructured to speed up international tax and transfer pricing cases Multinational companies operating in India can look forward to more timely resolution of cross-border tax and transfer pricing disputes after India’s Income Tax Appellate Tribunal (ITAT) agreed to devote separate... By Joe Dalton October 11 2012
US Tax Court dismisses whistleblower’s challenge to IRS US whistleblowers received some bad news this week when the Tax Court said it does not have the authority to make the IRS pursue a taxpayer’s case under any circumstances. By Joe Dalton October 11 2012
Japanese business says new carbon tax will exacerbate fallout from nuclear disaster Business lobbyists are attacking a new carbon tax that was introduced by the Japanese government on Monday, saying its implementation is ill-timed given that companies are still struggling in the... By Joe Dalton October 05 2012
Has PepsiCo’s US Tax Court win revealed “super factor” in deciding debt vs equity cases? In the latest US court ruling in a debt-versus-equity case, the 100-page judgment in the litigation concerning soft drinks company PepsiCo could help indicate the “super factor” in characterising a... By Joe Dalton October 04 2012
Commission refers UK to ECJ for failure to implement Marks & Spencer ruling The European Commission is referring the UK to the European Court of Justice (ECJ), claiming its cross-border loss relief rules still infringe EU law, despite amendments made after the Marks... By Joe Dalton October 04 2012
Dell case shows Spanish taxpayers must tread carefully over PEs A ruling by the Spanish Central Economic-Administrative Court (TEAC) against computer technology company Dell has narrowed the possibility for groups operating in Spain to declare they have no permanent establishment... By Joe Dalton October 04 2012
High Court sets November date for Fortescue Metals mining tax battle Australian iron ore company Fortescue Metals was granted leave by the High Court yesterday, to clarify the case it wants to bring against the government over the Minerals Resource Rent... By Joe Dalton October 04 2012
South Africa rejects taxpayer’s use of losses in Armgold mining case The South African Supreme Court of Appeal rejected the taxpayer’s and South African Revenue Service’s (SARS) arguments in its Armgold judgment this week, where it addressed the deduction of mining... By Joe Dalton October 04 2012
