ITR Search | International Tax Review

HMRC £1 billion transfer pricing yield may signal fast-track APA system

HM Revenue & Customs has collected more than £1 billion ($1.6 billion) in transfer pricing yield between March 2011 and 2012. Tax practitioners hope the high figure means more resources for the authority’s advance pricing agreements (APA) programme.

Sophie Ashley, August 29 2012

Canada presses ahead with corporate tax reforms

The Canadian government has released a document containing draft legislative proposals for a range of corporate tax reforms.

Matthew Gilleard, August 28 2012

Increasing tax information exchange in developing countries

Tom Aston of KPMG asks whether greater powers of information exchange will really benefit tax authorities in developing countries.

August 28 2012

Chidambaram’s comments put future of India’s DTC in doubt

India’s new Finance Minister Palaniappan Chidambaram has cast doubt over the future of the Direct Taxes Code (DTC), and now advisers say it may be permanently shelved.

Matthew Gilleard, August 28 2012

SABMiller fighting India over retrospective capital gains tax

Brewing multinational SABMiller filed a petition in Bombay’s High Court last week against the Indian tax authorities’ retrospective claims for unpaid capital gains tax, initiating a dispute that will ramp up the pressure on the government to overturn the retrospective amendments introduced in Finance Act 2012.

Joe Dalton, August 28 2012

What taxpayers should know about South Africa’s litigation strategy

South Africa’s tax regime is undergoing significant reform. International Tax Review speaks with two of the country’s leading tax advisers to discover how taxpayers can avoid disputes and what strategy the South African Revenue Service (SARS) is likely to pursue in the near future.

Joe Dalton, August 28 2012

Analysing the Canada-Australia DTA

TREATY ANALYSIS: Last month Australia and Canada announced they are in the process of renegotiating the double tax avoidance treaty between the two countries.

Matthew Gilleard, August 28 2012

How APAs can help tackle tax avoidance

Advanced pricing agreements (APAs) have long been hailed for the certainty they provide to taxpayers and authorities. But they can also be a useful tool in tackling avoidance with sufficient transparency.

Salman Shaheen, August 27 2012

Navigating India’s proposed GAAR

Proposed Indian general anti-avoidance rules (GAAR) were not met with much support when details were revealed earlier this year. But a recent consultation period has brought transparency and clarity to proposal, much to the benefit of taxpayers explains Rajendra Nayak of Ernst & Young.

August 27 2012

Transfer pricing investigation versus self-inspection

As transfer pricing enforcement evolves, the State Administration of Taxation (SAT) in China has developed the concept of anti-avoidance tax system combining management, service and investigation. Wu Duo and Li Ying of Siemens in China discuss the merits of transfer pricing investigation versus self-inspection.

August 27 2012

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