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Brendan Brown

Joel Williamson, Scott Stewart, and Kelsey Arnold of Mayer Brown review some key themes, such as economic substance, from US tax litigation since the 1990s. They predict a return to traditional statutory and regulatory arguments in the tax cases of the future

Mukesh Butani

Hatasakdi Na Pombejra

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

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.

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 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.

Under Brazil's federal constitution of 1988, the states of the federation and the federal district are entitled to establish tax on the "circulation of merchandise, on interstate and inter-municipal transportation services, and on communication services". The states' powers over this value-added tax, or Imposto sobre Operações relativas à Circulação de Mercadorias e Prestação de Serviços de Transporte Interestadual e Intermunicipal e de Comunicação (ICMS), are not unlimited, however. One limitation is found in article 155 §2 (XII) (g), which provides that a specific type of federal legislation known as a complementary law is required to grant ICMS exemptions and other benefits.