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.
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.
Polymetal, a Russian gold and silver producer, lost a transfer pricing dispute at the Supreme Arbitration Court last week, and the company says the ruling could affect the tax efficiency of hedging instruments related to sales of physical commodities.
In the News Limited ruling on Tuesday, Australia’s Federal Court ruled that currency exchange losses should not be limited only to the exchange of money, and this will give taxpayers confidence in claiming tax deductions for such losses in a broader range of circumstances.
Polymetal, a Russian gold and silver producer, has said its defeat in a transfer pricing case last week could affect the tax efficiency of hedging instruments related to sales of physical commodities.
