The Indian tax authorities are still arguing that UK-headquartered telecommunications multinational Vodafone must pay a $2.5 billion tax bill in relation to its 2007 acquisition of Hutchison Essar, the company has revealed.
Eastern Value Partners (Eastern Value), a subsidiary of Cyprus-based private equity group Exelor, with a permanent establishment in Russia, is entitled to tax benefits under the Russia-Cyprus double tax treaty (DTT) despite the tax authority’s claims it was treaty shopping, Russia’s Ninth Arbitration Court of Appeal has ruled.
The Gujarat High Court’s decision that the corporate veil can be lifted, for public as well as private companies, is a stark warning to tax evaders in India.
Steel production multinational Gerdau International (Gerdau) has beaten the Brazilian Internal Revenue Service (IRS) in an administrative-level appeal concerning the taxation of indirectly controlled foreign companies, but this is not the end of the battle.
Taxpayers often learn just as much from defeats in the courtroom as from their victories.
While decisions against the revenue authorities vindicate the positions companies take over their planning or structuring, losses help taxpayers to identify areas of greatest future risk and where the authorities are most likely to focus their attention.
