Switzerland’s upper house of Parliament approved a draft proposal to let the country’s banks forgo secrecy laws to appease the US yesterday, but some taxpayers may fear that tax information exchange agreements (TIEA) will see information transferred beyond the US.
Multinationals in India must maintain caution in their transfer pricing reporting of transactions involving investment into foreign subsidiaries even though the Hyderabad Income Tax Appellate Tribunal (ITAT) said transfer pricing rules do not apply in these circumstances.
If Vodafone accepts the Indian cabinet’s offer to enter a conciliation process under the Indian Arbitration and Conciliation Act to try and resolve its longstanding tax dispute, the Indian government may have to open up such a resolution mechanism to other multinationals.
HM Revenue & Customs’ (HMRC) head of dispute resolution, Val Hennelly, and Malcolm Twyman, an accredited mediator at HMRC, explained when taxpayers should consider using alternative dispute resolution (ADR) to resolve large and complex tax cases at an event hosted by accountancy firm BDO in London last night.
Multinationals in India must maintain caution in their transfer pricing reporting of transactions involving investment into foreign subsidiaries even though the Hyderabad Income Tax Appellate Tribunal (ITAT) said transfer pricing rules do not apply in these circumstances.
The court said that companies leaving Spain must have more flexibility on when they pay exit tax 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 Grid Indus and Portugal v Commission. But advisers say the ECJ is leaving important questions unanswered.