India’s Income Tax Appellate Tribunal Pune Bench (ITAT) recently decided a case concerning the tax deductibility of fees paid to portfolio managers, and if followed, the judgment could see the extension of deductions to other investment managers’ fees, advisers say.
South Africa’s tax regime is undergoing significant reform. International Tax Review speaks with two of the country’s leading tax advisers to discover how taxpayers can avoid disputes and what strategy the South African Revenue Service (SARS) is likely to pursue in the near future.
Brewing multinational SABMiller filed a petition in Bombay’s High Court last week against the Indian tax authorities’ retrospective claims for unpaid capital gains tax, initiating a dispute that will ramp up the pressure on the government to overturn the retrospective amendments introduced in Finance Act 2012.
In September the ECJ will re-open after its summer break. International Tax Review examines the tax schedule for next month and highlights the cases taxpayers will need to look out for.
A ruling by the US Court of Appeals for the Fifth Circuit concerning the transfer of funds from a closely held company to its sole board member provides valuable lessons for taxpayers as to how the courts will decide debt versus equity cases.
India’s Authority of Advance Ruling (AAR) has delivered a judgment which deviates from a High Court precedent, meaning foreign companies must carefully analyse the tax treatment of Indian permanent establishments (PEs) receiving royalties and fees for technical services (FTS) before structuring their operations in the jurisdiction.
