A recent victory for Copesul in Brazil’s Superior Court of Justice (STJ) should encourage companies relying on provisions of Brazilian double tax conventions (DTCs) to cut their effective tax rates.
The European Commission has said 99% of airlines flying to and from the EU complied with its March 31 2012 deadline for reporting emissions data under the emissions trading system (ETS), but global opposition to the scheme remains strong.
Tax authorities are increasingly engaging with one another to fight double non-taxation, and as the European Commission’s consultation on the issue closes next week, there is debate over the best approach to adopt.
Six claimants in the Franked Investment Income Group Litigation Order (FII GLO) had their claims for corporation tax refunds reinstated today, after a UK Supreme Court ruling said retrospective legislation issued by HMRC was in breach of EU law.
A report by the 2020 Tax Commission says the UK government should cut corporate tax rates, remove financial sector taxes and simplify tax rules to give the UK a tax system fit for the 21st Century.
If tax authorities are to combat double non-taxation then the application of targeted linking rules, and not harmonisation, is the only realistic option.
