ITR Search | International Tax Review

Tax on revenues and the non-cumulative principle

Brazil is one of the few countries that levies taxes on the total revenues of taxpayers. Glaucia Lauletta Frascino of Mattos Filho, Veiga Filho, Marrey Jr. e Quiroga looks at the complexities of the tax system and how they are causing problems for taxpayers.

March 31 2013

TIGTA gives Compliance Assurance Process positive marks but says user fees should be considered

Taxpayers in the US could have to pay to participate in the IRS’s Compliance Assurance Process (CAP) in the future, if a review by tax officials comes out in favour of charging user fees for the pre-filing programme that attempts to resolve any issues before a tax return is filed.

Ralph Cunningham, March 28 2013

High Court’s Nike ruling: How to ensure your Indian liaison office is not taxed

India’s Karnataka High Court has ruled in favour of US sports equipment group Nike, saying its liaison office (LO) cannot be taxed in India. The case delivers lessons for other foreign multinationals whose Indian LOs are engaged in operations relating to the purchase of goods.

Joe Dalton, March 28 2013

Brazilian Supreme Court ruling in Vernicitec case will cut taxes on imports

The Supreme Federal Court (STF) of Brazil’s judgment in favour of paint company, Vernicitec, last week will reduce the social contribution taxes levied on imports and could also impact another leading STF case on the inclusion of services tax when calculating the taxable basis for social contribution payments levied within Brazil.

Joe Dalton, March 28 2013

Canadian taxpayers to face more foreign-based information requirements in transfer pricing audits

The Canada Revenue Agency will be encouraged to increase its use of information gathering powers granted to it under the Canadian Income Tax Act during transfer pricing audits, after the Federal Court allowed its foreign-based information request to examine footwear retailer Soft-Moc’s tax affairs last week.

Joe Dalton, March 28 2013

IRS to release new procedures for APMA applications

The IRS will release new procedures governing advance pricing agreements (APA) and mutual agreement procedure (MAP) applications received by the advance pricing and mutual agreement (APMA) programme within the coming months.

Emma Powell, March 28 2013

Brazil: The impact of tax complexity on M&A activity

The complexity of the Brazilian tax system can take an unwary investor by surprise. Fabio Kenji Ota and Juliana Deslandes of Ernst & Young Terco explore the potential impact of this on M&A activity at this crucial time of increased positivity surrounding growth opportunities in Brazil.

March 27 2013

M&A tax changes in Germany 2012/2013

The German M&A market is picking up. Klaus Schmidt and André Gloede of PwC look at the tax changes which will affect deal-making.

March 27 2013

Kuwait considering introducing VAT

Talk of introducing VAT in the Gulf Cooperation Council (GCC) countries has been around for a while. Could Kuwait be the first to do so?

Salman Shaheen, March 27 2013

Desai made partner at BMR Advisors

Kalpesh Desai has been promoted to partner at BMR Advisors in Mumbai.

March 27 2013

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