ITR Search | International Tax Review

Treaties of the week - June 17 2013

Type of Agreement Country Country Date Signed Tax Information Exchange Agreement Botswana Isle of Man June 14 2013

June 16 2013

What you have missed on ITR Premium

UK Patent Box versus Dutch Innovation Box; Dave Camp on BEPS; Writ of payments benefits; Israel’s attempts to deny Medinol relief on Boston Scientific payout; Brazil scraps IOF on foreign investment in domestic bonds; Swiss VAT rise; EC’s tougher rules on EoI; Authorised tax collection in China.

June 16 2013

Dealing with the State Administration of Taxation in Chinese disputes

Vincent Pang, of KPMG, offers multinationals some guidance on reducing the risk of becoming involved in Chinese tax disputes, the options available for resolving disputes and the trends the Chinese tax authorities will follow in the next few years.

June 13 2013

Poland proposes abolishing APA annulment confidentiality

Poland’s Ministry of Finance has proposed changes to the country’s advance pricing agreement (APA) regime after reviewing the effectiveness of the programme over the past six years. However, if implemented, some proposals may reduce the popularity of the regime with taxpayers.

Emma Powell, June 12 2013

Israeli tax authority tries to deny Medinol relief on Boston Scientific payout

The Israeli tax authorities are claiming that medical technology firm Medinol owes between $150 and $225 million in capital gains tax on a $750 million compensation payout it received from US company Boston Scientific in 2005.

Joe Dalton, June 12 2013

Vodafone defends position in UK and Indian tax disputes

UK telecommunications group Vodafone has defended its position in its dispute with the Indian tax authorities and in the much scrutinised settlement with HM Revenue & Customs (HMRC) in 2010 in its sustainability report 2012/13. The report also includes an overview of the total tax contribution of the group on a country-by-country basis for the first time.

Joe Dalton, June 12 2013

Benefit of using writ of payment for taxpayers, states and the federal union

Renata Correia Cubas and Alessandra Gomensoro, of Mattos Filho, explain how using writ of payments benefits taxpayers paying debts in Brazil.

Joe Dalton, June 12 2013

No capital gains tax on acquiring Brazilian companies through incorporation of shares

Domestic and foreign companies acquiring Brazilian entities through the incorporation, as opposed to the sale, of shares should pay no capital gains tax, according to the country’s Administrative Council of Tax Appeals (Conselho Administrativo de Recursos Fiscais).

Joe Dalton, June 12 2013

Swiss move closer to ending US dispute over bank secrecy

Switzerland’s upper house of Parliament approved a draft proposal to let the country’s banks forgo secrecy laws to appease the US yesterday, but some taxpayers may fear that tax information exchange agreements (TIEA) will see information transferred beyond the US.

Joe Dalton, June 12 2013

Ukraine TP law: Why tomorrow’s risks must be addressed today

Historically, transfer pricing rules in Ukraine have been vague and were seldom applied by the Ukrainian tax authorities. Konstantin Karpushin, Anna Korobova and Oleksandra Tovkun of KPMG explain why taxpayers need to adopt a long-term view on their transfer pricing strategy.

June 11 2013

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