China’s State Administration of Taxation (SAT) implemented a measure for taxpayers to take advantage of mutual agreement procedures (MAP) for the resolution of cross-border tax disputes this month.
Multinationals in New Zealand have been told exactly what is expected of them in a new document outlining compliance requirements and the approach the Inland Revenue will take towards cross-border financing, controlled foreign companies and transfer pricing.
US multinational IBM is fighting a challenge from the Indian tax authorities over an exemption which it tried to claim on income generated from software exports.
Medical technology multinational, Medtronic, could suffer after the US Tax Court denied the company's request for a protective order in its transfer pricing case.
The Federal Prosecutor’s Office (MPF) in Brazil has issued an opinion against mining multinational Vale in its fight to show that the country’s controlled foreign company (CFC) rules unlawfully override double tax treaties.
Medical technology multinational, Medtronic, could suffer damaging consequences after the US Tax Court denied its request for a protective order in its transfer pricing case so it is important that other taxpayers understand why the court rejected the request.
A measure introduced by China’s State Administration of Taxation (SAT) to help taxpayers invoke the mutual agreement procedure (MAP) for the resolution of cross-border tax disputes took effect on Friday.
Joe Dalton reviews the key court cases in major jurisdictions that will impact multinationals next year, analysing the potential implications of the judgments for international tax planning.
The doctrine of legitimate expectation arises in UK disputes where HM Revenue & Customs (HMRC) has reversed its position on a ruling issued to a taxpayer to the detriment of the taxpayer. At a seminar hosted by PwC Legal in London on Monday, Sam Grodzinski QC, of Blackstone Chambers, highlighted the issue and explained how taxpayers should assess when a legitimate expectation argument will succeed.
Transfer pricing specialists at Standard Chartered, Citigroup and Nomura Securities expect the OECD’s base erosion and profit shifting (BEPS) project to have a significant impact for financial institutions but worry that new transfer pricing rules will be burdensome in what is already a highly regulated sector.
Taxpayers at International Tax Review’s Global Transfer Pricing Forum 2013 said they are already taking steps to ready themselves for the implementation of new tax rules and revenue authority approaches before the implementation of the OECD’s base erosion and profit shifting (BEPS) measures.
Taxpayers at International Tax Review’s Global Transfer Pricing Forum in Singapore reviewed the pros and cons of India’s new advance pricing agreement programme (APA), raising some concern over one of the features of the process - mandatory site visits from revenue officials.
US corporate tax reform could be good news for European multinationals if it forces other OECD countries to drive their own rates down yet further, according to a panel at the Irish Tax Institute’s global tax policy conference in Dublin today.
Pascal Saint-Amans, the OECD’s director for tax policy, today affirmed the base erosion and profit shifting (BEPS) action plan will be completed in two years, while European Commission tax head Philip Kermode said he backs the plan as long as it does not interfere with member states’ EU treaty obligations.
Energy multinational Cairn’s Delhi High Court win gives certainty for non-residents claiming the concessional tax rate of 10% on long-term capital gains arising on the disposal of listed securities in India.
Portuguese taxpayers could be entitled to tax refunds if they were denied interest deductions in relation to loans from non-EU entities, a European Court of Justice (ECJ) ruling has said.
Spanish banking group Santander’s surprising victory on summary judgment before the District Court of Massachusetts could undermine the government’s central argument in fighting the structured trust advantaged repackaged securities (STARS) cases.
Brazilian taxpayers involved in disputes centred on the country’s controlled foreign company (CFC) rules have been offered an amnesty if they withdraw their appeals. Law no. 12865, which was published today, establishes a special payment programme for companies willing to put an end to their CFC litigation.
The European Court of Justice’s (ECJ) decision to disallow the Belgian tax authorities’ attempt to turn exempt capital gains into taxable profits in the Gimle case gives taxpayers certainty on the accounting treatment of acquisitions and removes the need to undertake contrived intra-group transactions to obtain an exemption.
The Supreme Court of Canada has denied Envision Credit Union’s (Envision) strategy for avoiding tax upon amalgamation in a ruling which could have broader implications for the tax treatment of mergers in Canada.
Tax authorities need to follow information exchange protocol more carefully or risk having requests blocked, after the Australian Taxation Office (ATO) sought financial details about two Cayman Islands firms but was blocked by the UK territory’s Grand Court.
Clothing retailer Grattan’s UK First-tier Tax Tribunal (FTT) defeat showed that fiscal neutrality is an aid to interpreting VAT directives, not a rule of substantive law. However, that does not mean taxpayers cannot still win with arguments based on the principle.
The Robin Hood Tax campaign group says the FTT will still be successful The EU member states introducing the financial transaction tax (FTT) may be forced to water down the European Commission's proposal if they want to make it stick, after the EU Council's legal service said part of the residence principle of the tax is incompatible with European law.