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  • Alex Salmond, Scotland’s First Minister, has dubbed the rise in windfall tax on the oil sector as “cack handed” and criticised the UK government for failing to run a consultation before the rise from 20% to 32% introduced in this year’s budget.
  • The OECD project on the transfer pricing aspects of business restructuring has clarified a lot of the issues around the topic since it began in 2005, but uncertainties still remain, the annual congress of the International Fiscal Association (IFA) was told on Monday.
  • Paul Smith and Wendy Nicholls of Grant Thornton UK welcome the new patent box proposals but believe the take-up will be small because of the restriction to patents and the highly complicated calculation of patent box profits.
  • The District Court of the Hague has ruled, in a transfer pricing dispute, that the profits of an Irish reinsurance company are considered taxable income for its Dutch shareholder. Eduard Sporken and Dirk Brouwers of KPMG Meijburg & Co discuss the case and its implications.
  • Revisions of previous guidance is showing signs of a more conciliatory approach by the UK tax authorities. However they are still prepared to litigate, points out Helen Buchanan of Freshfields Bruckhaus Deringer
  • Manuel Sainz Orantes and Alejandro Torres Rivero of Chevez, Ruiz, Zamarripa y Cia discuss how tax litigation has changed in Mexico, noting that the tax authorities are complying more with the law. However, recent Supreme Court judgments have not always abided by legal provisions
  • Machiel Lambooij Freshfields Bruckhaus Deringer
  • Vittorio Salvadori di Wiesenhoff Freshfields Bruckhaus Deringer
  • Brendan Brown
  • The Argentine tax authorities have become more aggressive in recent years, particularly in transfer pricing matters, and have not been afraid to take legal action against taxpayers, reports Juan Manuel Soria Acuña of MCRLex