ITR Search | International Tax Review

Danish exit tax disallowed but ECJ says states can tax alternative events to realisation

The European Court of Justice (ECJ) has followed its decisions in previous exit tax cases such as National Grid Indus by declaring Denmark’s rules against EU law, but has added that member states are permitted to define additional taxable events to charge taxpayers whose assets may never be realised.

Joe Dalton, July 31 2013

OECD’s plan to simplify documentation requirements could have the opposite effect

The OECD has released a white paper on transfer pricing documentation, which proposes a two-tier approach that would require taxpayers to submit a global master file along with country-specific transaction information. However the proposals could result in an increased compliance burden for businesses, according to one revenue authority official.

Emma Powell, July 31 2013

Transfer pricing and related parties disclosures

To ensure the respect of the arm’s length principle, Italian Law mandates that companies’ financial statements include proper disclosures regarding transactions with related parties. Piergiorgio Valente, managing partner of Valente Associati GEB Partners explains the logistics of the Italian rules.

July 31 2013

French guidelines on e-invoicing need more clarity on practical implementation

The French tax authorities have issued draft guidelines for e-invoicing rules, in line with an EU Directive. However, there is still uncertainty about what methods for producing digital invoices will be accepted.

July 30 2013

Edmund Leow steps up to Supreme Court in Singapore

Eugene Lim will become the head of Baker & McKenzie.Wong & Leow’s tax and wealth management practice in Singapore at the end of August, when Edmund Leow leaves the firm to become a judicial commissioner, with the powers of a judge, of the country’s Supreme Court.

July 30 2013

Jerald Wortsman joins Torys

Jerald Wortsman has joined Torys in Canada as a partner in its tax group. His practice focuses on M&A, domestic and international tax planning, reorganisations and corporate finance. He was formerly with McCarthy Tétrault.

July 30 2013

Joint group to deal with interpretations of revenue recognition accounting standard

The International Accounting Standards Board (IASB) and the Financial Accounting Standards Board (FASB) are to set up a group to deal with different interpretations arising from the final converged standard on revenue recognition, which is due to be released before the end of September.

Ralph Cunningham, July 30 2013

Deferred taxes related to foreign interest – what you should consider under IAS 12

Investing in subsidiaries, branches or associates, as well as having interest in a joint venture, would trigger some consequences from a deferred tax standpoint.

July 30 2013

South Africa releases details of VAT registration procedure for e-commerce

The South African National Treasury has released a Bill for public comment, which would force foreign suppliers of e-commerce services to register for VAT in South Africa.

July 30 2013

How to build a simpler and more harmonised operational transfer pricing system

Taxpayers are demanding better automated and centralised systems for calculating their transfer pricing. However there is still some way to go before the use of harmonised operational models become standard within business.

Emma Powell, July 29 2013

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