ITR Search | International Tax Review

European Commission weighs against Wheels in DB ECJ VAT case

A case involving a number of Ford Motor Company defined benefit (DB) pension funds was heard by the European Court of Justice (ECJ) last week, with an annual £100 million in VAT at stake.

Salman Shaheen, September 19 2012

How to choose branches or subsidiaries in your corporate structure

A constant issue faced by multinational taxpayers is whether branches or subsidiaries are a more useful and flexible part of the corporate structure and in what circumstances it is appropriate to employ one over the other.

Matthew Gilleard, September 18 2012

European Commission advisers want improvements to IAS 12 proposal

More work is required before an amendment to IAS 12, the international accounting standard that deals with accounting for income taxes, is finalised, says EFRAG, the body that advises the European Commission on the technical quality of international financial reporting standards (IFRS).

September 18 2012

CASE ANALYSIS: Why the ECJ’s Philips ruling could have far-reaching consequences

The European Court of Justice (ECJ) ruled that the UK’s loss relief rules for branches infringe EU law in the Philips Electronics case this month, raising the opportunity for similarly structured groups to bring claims. But the case could have knock-on effects for other taxpayers and open up new lines of attack for taxpayers in future loss relief cases.

Joe Dalton, September 18 2012

SARS requests information on customs and transfer pricing

The South African Revenue Service (SARS)’s new notice about retroactive transfer pricing adjustments is an attempt to establish if taxpayers are compliant with customs legislation.

Sophie Ashley, September 17 2012

Getting the most from the Ukrainian APA programme

Ukraine’s advance pricing agreement (APA) programme is an attempt to improve the country’s transfer pricing system but uncertainty remains for taxpayers.

Sophie Ashley, September 17 2012

UK GAAR reaction reveals serious constitutional problems

The consultation period for the government’s proposed general anti-abuse rule (GAAR) came to a close at the end of last week, with respondent stakeholders saying there are serious problems with the proposal.

Matthew Gilleard, September 17 2012

Indian Supreme Court gives Essar more time to pay sales tax

Essar Oil will be able to repay the $939 million in sales tax owed to the Indian government in eight quarterly instalments, after a Supreme Court ruling.

Joe Dalton, September 17 2012

Canada’s proposed foreign affiliate dumping rules: The “shotgun” approach to tax legislation

Last Thursday, September 13, was the deadline for comments to the Canadian Department of Finance on draft legislation released on August 14 2012, implementing changes announced in the March 2012 budget. The most contentious of these are new foreign affiliate dumping rules.

September 17 2012

How US state and local tax issues impact mergers and acquisitions

One of the most frequently misunderstood and complex areas for foreign companies acquiring a business based in the US is accurately assessing the state and local tax liabilities of the target company.

September 17 2012

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