The Philippines Court of Tax Appeals (CTA) refused a refund claim for overpaid VAT by Dumex last week because it could not provide a certificate of tax clearance to prove it had no outstanding tax liabilities.
Brazil’s Supreme Federal Tribunal (STF) has determined that an appeal case regarding the constitutionality of the country’s controlled foreign company (CFC) rules will have general repercussions, meaning the decision will be binding on the lower courts.
Germany is amending its transfer pricing laws so transactions between permanent establishments (PEs) will be treated the same as those between subsidiaries, leading to exit taxes on the transfer of functions.
A measure introduced in last month’s Finance Bill will enhance the powers of transfer pricing officers (TPOs) to audit international transactions which have not been referred by assessing officers (AOs), possibly because of non-disclosure by taxpayers.
The OECD’s Global Forum on Transparency and Exchange of Information identified serious deficiencies in the domestic laws of Costa Rica and Guatemala for exchange of tax information purposes.
