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St Michael Trust Corp loses Canada SC battle

St Michael Trust Corp has today lost its Supreme Court of Canada (SCC) battle over the tax residence of a trust.

Jack Grocott, April 11 2012
Foster leaves Olswang

Field Fisher Waterhouse has a new contentious tax partner in London.

April 11 2012
Dumex ruling highlights need for Philippines documentation

The Philippines Court of Tax Appeals (CTA) refused a refund claim for overpaid VAT by Dumex last week because it could not provide a certificate of tax clearance to prove it had no outstanding tax liabilities.

Joe Dalton, April 11 2012
HMRC reveals future for ADR in the UK

Last week HMRC finalised its litigation settlement strategy (LSS) and alternative dispute resolution (ADR) guidance. International Tax Review speaks to Val Hennelly, HMRC’s head of dispute resolution about what this means for taxpayers involved in disputes.

Jack Grocott, April 11 2012
Companies must use German PEs for business restructuring before law change

Germany is amending its transfer pricing laws so transactions between permanent establishments (PEs) will be treated the same as those between subsidiaries, leading to exit taxes on the transfer of functions.

Joe Dalton, April 10 2012
Shulman outlines future for US tax compliance

The head of the Internal Revenue Service (IRS) has said his organisation is in the process of reshaping its large business compliance strategy so that it looks at the objectives of the taxpayer and what they want to achieve through their tax planning, rather than ensuring adherence to different sections of the Internal Revenue Code.

Ralph Cunningham, April 10 2012
Tuerff gets bigger Deloitte role

Deloitte’s Washington National Tax (WNT) practice has a new leader.

April 10 2012
Ex-Indian official explains why Vodafone had a lucky escape

In an exclusive interview with International Tax Review, Girish Srivastava, ex-Director General of Income Tax (International Taxation) in the Indian government talks Vodafone, retrospective amendments, and why taxpayers should expect to lose their battles with officials.

April 10 2012
India’s officials given enhanced powers to audit international transactions

A measure introduced in last month’s Finance Bill will enhance the powers of transfer pricing officers (TPOs) to audit international transactions which have not been referred by assessing officers (AOs), possibly because of non-disclosure by taxpayers.

Joe Dalton, April 09 2012
SARS to invest more in transfer pricing training

The South African Revenue Service (SARS) has announced a renewed focus on transfer pricing, which will include investment in training for its staff.

Sophie Ashley, April 09 2012

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