A Milan tax court has dismissed an appeal by Italian fashion house Dolce & Gabbana in a dispute over the transfer of the company's brands to Luxembourg. The ruling shows the Italian tax authorities are particularly suspicious of reorganisations involving certain jurisdictions, advisers say.
Brazilian taxpayers remain in suspense after the Supreme Federal Court (STF) began its judgment in Extraordinary Appeal 611,586 on the constitutionality of Brazil’s controlled foreign company (CFC) rules yesterday, only to suspend the full verdict until next week.
India’s Karnataka High Court has ruled in favour of US sports equipment group Nike, saying its liaison office (LO) cannot be taxed in India. The case delivers lessons for other foreign multinationals whose Indian LOs are engaged in operations relating to the purchase of goods.
The Supreme Federal Court (STF) of Brazil’s judgment in favour of paint company, Vernicitec, last week will reduce the social contribution taxes levied on imports and could also impact another leading STF case on the inclusion of services tax when calculating the taxable basis for social contribution payments levied within Brazil.
The Canada Revenue Agency will be encouraged to increase its use of information gathering powers granted to it under the Canadian Income Tax Act during transfer pricing audits, after the Federal Court allowed its foreign-based information request to examine footwear retailer Soft-Moc’s tax affairs last week.
New Zealand taxpayers will be worried the country's general anti-avoidance rule (GAAR) is increasingly being used to effectively re-write deficient legislation and to set aside specific legislation, after the Court of Appeal found against Alesco in a tax avoidance case.
