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UK taxpayers should amend open returns to benefit from High Court Prudential ruling

UK taxpayers will need to amend any open returns to show foreign portfolio income as carrying a tax credit following the England and Wales High Court's ruling in the Prudential case last week.

October 31 2013

UN Tax Committee sets out work programme until 2017

Tax treaties, services, the extractive industries and exchange of information are all on the agenda for the next four years of the UN Tax Committee, reports David Spencer, a delegate at the committee’s annual meeting in October.

October 31 2013

Brazil amends transfer pricing regulations for commodities

The Brazilian Federal Revenue Office (RFB) has enacted Normative Instruction (IN RFB) 1,395/2013, with the intention of amending and clarifying IN RFB 1,312/2012, which provided guidance on the PCI (price valuation on imports method) and PECEX (price valuation on exports method) methods.

October 30 2013

Biggest British energy firms create “straw man” of green taxes to hike prices

Four of the six largest UK energy companies have now hiked their prices by more than 9%. The companies blame green taxes, but critics say this is a smokescreen to cover their big profits.

Salman Shaheen, October 30 2013

Financial institutions get glimpse of draft FATCA agreement

The US Treasury Department and Internal Revenue Service (IRS) yesterday published draft guidance and an agreement for foreign financial institutions (FFIs) under the Foreign Account Tax Compliance Act (FATCA), as well as intended updates to the regulations under the legislation.

Ralph Cunningham, October 30 2013

Nice Cheer accuses Commissioner of applying extraordinary accounting standard in HK’s top court

Hong Kong’s highest court is deciding whether unrealised gains should be treated as profits for tax purposes after hearing the arguments in the Nice Cheer Investment case. The Court of Final Appeal’s (CFA) decision should finally settle the distinction to be drawn between legal principles and ordinary commercial accounting principles.

October 30 2013

German Federal Fiscal Court on soccer clubs: No VAT deduction for players’ agent commissions?

The German Federal Fiscal Court passed its judgment (XI R 4/11) regarding VAT deduction for players’ agent commissions on August 28 2013. The key question is whether the players’ agents render services to the soccer club, writes Oliver Zugmaier of küffner maunz langer zugmaier.

October 30 2013

Banks concerned about BEPS-driven TP rules adding to existing regulatory burden

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.

Joe Dalton, October 29 2013

Corporate tax in 2014: The US perspective

Al Groff, Washington DC based partner at Shearman & Sterling, shares his insights into the year ahead, outlining an optimism for US tax reform that is not shared by all, concerns about reporting obligations, and hopes for a continued pick-up in deal activity.

Matthew Gilleard, October 29 2013

Drifting away: International tax revenue lost in the e-commerce cloud

The internet has made international borders inconsequential for e-commerce and business transactions, leaving countries with the challenge of developing a workable tax policy for those online dealings.

October 29 2013

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