The Israeli tax authorities are claiming that medical technology firm Medinol owes between $150 and $225 million in capital gains tax on a $750 million compensation payout it received from US company Boston Scientific in 2005.
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.