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OECD lines up next transfer pricing chief after Joe Andrus

If you think you are the right person to lead the OECD’s transfer pricing unit, start dusting off your resumé and perfecting your interview technique.

September 29 2013

Has US Tax Court’s concession to BNY Mellon opened new chapter in STARS cases?

The Bank of New York Mellon’s (BNY Mellon) US Tax Court victory on Monday could see a new wave of taxpayer claims in structured trust advantaged repackaged securities (STARS) cases.

Joe Dalton, September 25 2013

BB&T loses STARS case but ruling clouds legitimate tax planning rights in US

US bank BB&T is considering appealing Friday’s Court of Federal Claims defeat, despite the case judge describing its tax credit generator scheme with Barclays as an economically meaningless tax shelter. While some advisers and academics say the decision is unhelpful for taxpayers undertaking legitimate tax planning.

Joe Dalton, September 25 2013

IRS says it is implementing plans to measure success of Compliance Assurance Process

The Government Accountability Office (GAO) in the US has criticised the Internal Revenue Service (IRS) for failing to evaluate whether the goals of its Compliance Assurance Process (CAP) are being met and whether to expand the progamme.

Ralph Cunningham, September 25 2013

HMRC upping ADR capacity for large taxpayers after successful pilot

HM Revenue & Customs (HMRC) has published an evaluation of its pilot on alternative dispute resolution (ADR) for large and complex tax cases, and says it will up its mediation capacity after ADR proved to be a useful tool in resolving entrenched disputes.

Joe Dalton, September 25 2013

Irish Revenue Commissioners reviewing 12 multinationals’ TP compliance

After the European Commission’s announcement it is investigating Ireland, Luxembourg and the Netherlands in relation to preferential tax rulings, the Irish Revenue Commissioners say they are reviewing the transfer pricing practices of 12 multinationals.

Joe Dalton, September 25 2013

Compensating adjustment mechanism: Another loophole closed

The UK government is changing the compensating adjustment mechanism in its transfer pricing legislation, which will affect services companies and loans from individuals or partnerships to companies that are more than the arm’s-length amount of debt.

Sophie Ashley, September 25 2013

Germany: Entry certificate for zero-rated supplies within the EU

After a long time of discussions and after many postponements, the obligation to provide proof for zero-rated intra-Community supplies finally changes with effect from October 1 2013, writes Ronny Langer of küffner maunz langer zugmaier.

September 24 2013

Taxpayers struggling with VAT legislation in Romania

The Romanian VAT legislation has been causing taxpayers in the jurisdiction significant problems.

Jamie Moore, September 24 2013

Ed Miliband: UK Labour Party would raise corporation tax

Ed Miliband, leader of the UK opposition Labour Party, has said he would reduce the tax burden on small businesses at the expense of big corporations by raising the corporate tax rate if elected.

Matthew Gilleard, September 23 2013

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