International Tax Review speaks with three of the UK’s leading tax dispute advisers to get advice on managing UK disputes and find out what taxpayers can expect from HMRC in future.
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 for Advance Rulings (AAR) has said a Mauritius tax residency certificate is sufficient to benefit from the India-Mauritius double taxation avoidance convention, but taxpayers may only be safe until the general anti-avoidance rule (GAAR) is introduced in April 2013.
Taxpayers can look forward to earlier, more cost effective dispute resolution after the Australian Taxation Office (ATO) agreed to several recommendations in a recent report published by the Inspector-General of Taxation (IGT).
The European Court of Justice (ECJ) dealt a blow to discretionary fund managers (DFMs) in the Deutsche Bank case last week when it said they must charge VAT on their services, but there are options available to limit the harm this will cause, according to advisers.
A recent judgment by Canada’s Federal Court of Appeal (FCA) found in favour of an individual taxpayer against the Canada Revenue Agency’s (CRA) attempts to tax gains realised from a foreign trust, but the judge’s analysis of the Canada-Austria income tax convention could have wider ramifications.
