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In a recent decision, the Supreme Federal Court of Brazil, which has jurisdiction over constitutional issues, acknowledged the need to examine whether the Brazilian Federal Constitution was violated by decisions of the Superior Court of Justice regarding Decision No. 106 to rule that the applicable statute of limitations will be tolled for purposes of tax debts, and therefore the right of Brazil’s tax authorities to make tax assessments will be maintained, where a matter is not adjudicated because of delays by the Judiciary.

US taxpayers who seek to exploit the differences in the tax treatment of debt and equity will need to prepare for more aggressive enforcement by the Internal Revenue Service (IRS). The decisions in three recent court cases, all featured in this International Tax Review special focus, suggest how companies could deal with this approach from the tax authorities.

Type of Agreement Country Country Date Signed Tax Information Exchange Agreement Argentina India January 27 2013 Tax Information Exchange Agreement Canada Uruguay February 5 2013 Tax Information Exchange Agreement Brazil Guernsey February 6 2013 Double Taxation Avoidance Agreement Guernsey Singapore February 6 2013

Australian regulation; IRS information reporting councils; bonus deferral; US economic recovery; Indian indirect tax; OECD VAT draft; ATO High Court; BGZ Leasing case

Russian taxpayers now have an opportunity to create a better way of working with the tax authorities.

Shell India will challenge a claim by the Indian tax authorities that it undervalued shares issued to a foreign subsidiary on the grounds that the order is contrary to tax regulations. If Shell is unsuccessful the outcome could influence other multinationals to change their valuation method for share issuance.

The Danish tax authority, SKAT, has published its transfer pricing statistics, which show an increase in revenue from transfer pricing assessments, particularly through intellectual property (IP) transactions.

A lack of international consensus on the treatment of liquidity buffers, required under Basel III, is leaving banks exposed to the risk of double taxation.

Becoming embroiled in a Colombian tax dispute is a lengthy and costly business because the tax authorities are banned from settling disputes, meaning taxpayers are forced into litigation. But there are some options for taxpayers, including a respite period under the recently enacted Tax Reform Act 2012.

The Australian Taxation Office’s (ATO) response to the High Court’s judgment in the Mills case, where the taxpayer escaped the general anti-avoidance rule (GAAR), shows an acceptance the ruling is not limited to tier one capital raising by banks. The response could also help taxpayers outlining GAAR defences in future litigation.