Australian iron ore company Fortescue Metals was granted leave by the High Court yesterday, to clarify the case it wants to bring against the government over the Minerals Resource Rent Tax (MRRT).
In the latest US court ruling in a debt-versus-equity case, the 100-page judgment in the litigation concerning soft drinks company PepsiCo could help indicate the “super factor” in characterising a structure.
The European Commission is referring the UK to the European Court of Justice (ECJ), claiming its cross-border loss relief rules still infringe EU law, despite amendments made after the Marks & Spencer ruling.
The South African Supreme Court of Appeal rejected the taxpayer’s and South African Revenue Service’s (SARS) arguments in its Armgold judgment this week, where it addressed the deduction of mining capital expenditure for taxpayers operating multiple mines.
Taxpayers, revenue authorities and the courts are seeing increasing numbers of transfer pricing disputes being settled earlier, avoiding court hearings, a panel at International Tax Review’s Global Transfer Pricing Forum identified.
