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  • Multinational companies in Italy and the risk of hidden permanent establishment
    On March 2 2011 the Court of Appeals in Oslo issued sentence no. 2011-17 which has revived the topic of hidden permanent establishment.
    June 01 2011
  • OECD opens model tax convention to all countries
    On June 1 the OECD announced new amendments to its multilateral tax convention, making all countries eligible to participate in the agreement.
    June 01 2011
  • BHP Billiton wins $580 million in dispute with Australian Commissioner
    The High Court of Australia ruled on Wednesday in favour of BHP Billiton after a lengthy dispute between the mining company and the Australian Taxation Office (ATO), awarding BHP a $580 million tax credit.
    Matthew Gilleard, June 01 2011
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    Delays ahead for intangibles project
    The resignations of Mary Bennett and Caroline Silberztein from the OECD last week provoked wide-spread speculation, above all because their jobs were advertised simultaneously, suggesting all is not well in the OECD’s corridors of power.
    May 31 2011
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    Austria intangibles guide
    By Marianna Dozsa and Bettina Dorfer PwC, Austria
    May 31 2011
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    Adjustments to business conditions
    Cristiane Magalhaes and Victoria Rozsavolgyi of Machado Associados, Brazil, comment on the main aspects and difficulties of the adjustments to business conditions allowed by the Brazilian transfer pricing legislation in part one of a two-part investigation.
    May 31 2011
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    China broadens audit focus
    The Chinese State Administration of Taxation (SAT) has broadened its audit focus and will pay more attention to intangibles, controlled foreign companies (CFC) and thin capitalisation.
    May 31 2011
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    Obama administration questions TP law
    Two recent cases in the US, Medtronic and Guidant, highlight the Obama administration’s budget proposals to clarify the law regarding foreign intangible assets.
    May 31 2011
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    OECD to shape ALP for developing countries
    The OECD ministerial meeting in Paris had a strong focus on both tax and the developing world and, as such, transfer pricing issues were also raised.
    May 31 2011
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    Chief judge champions US tax court’s approach
    Lawyers used to practising in US district courts may be surprised to see that things are done differently in the national tax court. In an interview at the court in Washington DC, Chief Judge John Colvin explains to Erin Kelechava that the tax court places a greater emphasis on pre-trial procedures in the hope of achieving a more efficient resolution of the case on the merits.
    May 31 2011
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