An Advocate General of the European Court of Justice (ECJ) has released an opinion regarding inclusion of non-taxable persons in VAT groups that will be welcomed by taxpayers and revenue authorities.
India’s Income Tax Appellate Tribunal (ITAT), Kolkata bench, ruled that distributing dividends immediately before a share sale to reduce capital gains tax liability is acceptable tax planning. But, changes to India’s capital gains tax regime for non-residents mean the scheme will only benefit some taxpayers.
D’Ascenzo hopes other taxpayers will follow Alcoa’s lead and enter more comprehensive ACAs Alcoa, the multinational aluminium producer, recently signed an Annual Compliance Arrangement (ACA) that was described by Australian Tax Commissioner Michael D'Ascenzo as "historic" because of its comprehensive nature. International Tax Review looks at whether such a broad ACA is best for taxpayers. The Australian Taxation Office (ATO) introduced ACAs in 2008 as an administrative arrangement defining and governing the compliance relationship between the ATO and taxpayers.
Canadian taxpayers whose business is acquiring companies may still be able to file break fees received under a pre-acquisition agreement on capital account, despite the Federal Court of Appeal’s (FCA) ruling in the Morguard Corporation case last week, according to an adviser.
Multinationals can raise capital in Australia and pay distributions to Australian resident investors out of foreign source income with imputation benefits attached, after the High Court’s ruling in a general anti-avoidance rule (GAAR) case involving the Commonwealth Bank of Australia (CBA).