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.
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.
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).
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.
France’s recently elected Socialist government has already announced new tax policies aimed at large companies, with changes to anti-abuse and controlled foreign company rules likely to lead to more tax authority challenges next year.
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.
