ITR Search | International Tax Review

UK updates CFC excluded territories exemption

The Treasury is now inviting stakeholder comments on the revised draft

Matthew Gilleard, August 31 2012

The UK GAAR: What needs answering

The general anti-avoidance rule (GAAR) is set to become the UK tax authorities’ latest tool for targeting and counteracting tax avoidance. Sandy Bhogal and Ben Fryer of Mayer Brown analyse the consultation, and assess how such a rule will affect taxpayers.

August 31 2012

Australia to reform its general anti-avoidance regime

After a series of court losses suffered by the Commissioner of Taxation, Australia's general anti-avoidance regime (GAAR), part IVA, looks set to undergo a significant modification to its scope and application. Mark Friezer and John Boyagi of Clayton Utz explore the reasons motivating the reform and why taxpayers need to keep track of the changes.

August 31 2012

The future for BRICS tax policy coordination

The BRICS members are important players on the world’s economic stage and are working more closely together in this sense. But tax policy remains primarily the preserve of individual nations. Salman Shaheen looks at tax policy priorities for the BRICS and the areas in which they should work more closely together in the future.

August 31 2012

Practical transfer pricing in the BRICS

The BRICS represent five significant transfer pricing jurisdictions for taxpayers. All of them are big investment targets but each of them has a different transfer pricing regime to adhere to. Litigation is on the up in all of them. Sophie Ashley provides an overview of the trends and pitfalls taxpayers are facing in the BRICS and how to get around them.

August 31 2012

Increased focus on tax governance

Mak Oi Leng of KPMG in Singapore explains why corporate stakeholders such as boards of directors, tax directors, chief executive officers and chief finance officers should all have a vested interest in their company’s tax governance.

August 31 2012

Canada – US arbitration: Too soon to pass judgment

Brad Rolph of Charles River Associates in Canada takes a closer look at the memorandum of understanding (MOU) on arbitration between the US and Canada and the accompanying arbitration board operating guidelines. He also examines whether the arbitration procedure is accomplishing its objectives to reduce the amount of time it takes to resolve double taxation cases and increase the use of principle-based negotiating positions.

August 31 2012

FATCA – How ready are you?

Tom Walsh, managing director, global customs trade and trust, for the tax & accounting business of Thomson Reuters, explains why there is a lack of confidence among firms that implementation deadline can be met.

August 31 2012

Analysing the OECD draft on intangibles

Issues involving intangibles likely account for the majority of transfer pricing disputes, by dollar volume, in most major countries throughout the tax world. This trend is expected to continue in future years. Todd Wolosoff and David Cordova of Deloitte Tax discuss the OECD’s recent draft on the transfer pricing aspects of intangible assets.

August 31 2012

Myanmar’s tax on non-residents on the eve of a leap in FDI

The lifting of US sanctions on general investment in Myanmar is one of the key indications that this Southeast Asian frontier market is poised for a big leap in terms of foreign direct investment (FDI). Cynthia Herman, Edwin Vanderbruggen and Thida Cho Win of VDB Loi discuss how non-residents will be taxed.

August 31 2012

Search results for