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.
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.
The Supreme Court of the Netherlands has delivered a judgment which allows a Dutch taxpayer to deduct losses incurred on a related party loan, creating an exception to the shareholder loan doctrine set out by the court in November 2011.
