ITR Search | International Tax Review

Why Italian taxpayers are turning to alternative dispute resolution

Italian taxpayers are increasingly turning to alternative dispute resolution (ADR) to settle transfer pricing disputes in a trend advisers say was initiated by the recent release of guidelines clarifying the MAP process.

Joe Dalton, August 22 2012

Treatment of forex gains and losses in transfer pricing

Enterprises engaged in cross-border transactions bear forex risks and consider this when setting the prices/margins if such risks are not passed on to their counterparts.

August 22 2012

India’s AAR rules on taxing PEs in Geondata case

India’s Authority of Advance Ruling (AAR) has delivered a judgment which deviates from a High Court precedent, meaning foreign companies must carefully analyse the tax treatment of Indian permanent establishments (PEs) receiving royalties and fees for technical services (FTS) before structuring their operations in the jurisdiction.

Joe Dalton, August 22 2012

Taxpayers’ guide to UK disputes and HMRC’s litigation strategy

International Tax Review speaks with three of the UK’s leading tax dispute advisers to get advice on managing UK disputes and find out what taxpayers can expect from HMRC in future.

Joe Dalton, August 22 2012

Calls for UK-style FATCA criticised

A group of UK politicians is calling for a British version of FATCA to help stem cross-border tax evasion, but this demand has been criticised for being unrealistic.

Jack Grocott, August 22 2012

US Court of Appeals ruling sheds light on debt vs equity

A ruling by the US Court of Appeals for the Fifth Circuit concerning the transfer of funds from a closely held company to its sole board member provides valuable lessons for taxpayers as to how the courts will decide debt versus equity cases.

Joe Dalton, August 22 2012

Deloitte US extends partnerships

Deloitte has promoted Kristine Riisberg to partner in its transfer pricing department.

August 21 2012

Why India is struggling to implement IFRS

At the end of 2011, advisers told International Tax Review that India has too many obstacles to overcome before IFRS can be implemented. Eight months on, one leading adviser argues that the same problems persist.

August 21 2012

ISDA releases protocol to tax FATCA derivative transactions

The International Swaps and Derivatives Association (ISDA) has released a new protocol to deal with a provision in FATCA, that could subject derivative transactions to a 30% withholding tax on certain US-sourced payments.

Jack Grocott, August 21 2012

India names new CBDT chairwoman

The Indian Ministry of Finance has confirmed Poonam Kishore Saxena has been appointed as chairwoman of the Central Board of Direct Taxes (CBDT), effective immediately.

August 21 2012

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