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.
Italian taxpayers are increasingly turning to alternative dispute resolution (ADR) to settle transfer pricing disputes in a trend advisers say was initiated by the recent release of guidelines clarifying the MAP process.
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).
An Advocate General of the European Court of Justice (ECJ) released an opinion last week which gives the court the option of reversing its original decision in the Franked Investment Income Group Litigation Order (FII) case.
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.
