India’s tax authority has filed a special leave petition with the Supreme Court attempting to overturn the High Court’s ruling in the Sanofi case, and is also asking the court to reassess the principles set down in its Vodafone judgment.
Energy groups with petroleum projects in Australia need to change the way they document expenditure to ensure they can successfully substantiate exploration expense deductions, following a judgment published by the country’s Administrative Appeals Tribunal (AAT) yesterday.
US multinationals should see their transaction costs reduced when investing in foreign jurisdictions following the Supreme Court’s judgment in favour of energy company PPL.
The UK Supreme Court dismissed HM Revenue & Customs’ (HMRC) appeal in the first part of its judgment in the Marks & Spencer (M&S) dispute. The court’s answer means taxpayers will have more flexibility when claiming cross-border group relief.
Germany’s intent to incorporate mandatory binding arbitration provisions in current and future double taxation agreements (DTA) should allow taxpayers to eliminate the risk of double taxation in cross-border cases and help them exert pressure on tax authorities to reduce the length of disputes.
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 what remains an area of legal uncertainty in India.
