Tax heads of multinational companies say the UK Supreme Court's decision in the Prudential case, which said legal advice privilege (LAP) only protects communications between taxpayers and lawyers, will not make them choose lawyers above accountants for tax legal advice.
Foreign investors using holding companies to acquire UK entities need to learn from the mistakes made by Spanish multinational Ferrovial after it used Airport Development and Investments Limited (ADIL) as a vehicle to acquire airport operator BAA (now Heathrow) if they want to recover input VAT.
Taxpayers affected by the European Commission's financial transaction tax (FTT) and member states outside of the FTT zone should consider mounting challenges over the legality of the tax, advisers say.
PPL Corporation (PPL) kicked off its appeal over the creditability of UK windfall tax for US foreign tax credit purposes in the US Supreme Court yesterday. If the judgment causes uncertainty about which foreign taxes are creditable in America it could affect the way US taxpayers invest abroad.
French pharmaceutical multinational Sanofi’s victory in the Andhra Pradesh High Court shows the retrospective amendments to India’s tax laws cannot override the provisions of a tax treaty and sends a strong signal to foreign investors that India’s judiciary will uphold their interests.
