ITR Search | International Tax Review

Court of Appeal rules that a commissionaire company constitutes an agency PE of its principal company

Hans Martin Jorgensen Nick Pearson-Woodd A Norwegian Court of Appeal ruled on March 2 that Dell AS, a Norwegian commissionaire company, constituted a dependent sales agency permanent establishment (PE) in Norway for its undisclosed Irish principal. Dell has sought leave to appeal the decision to Norway's Supreme Court.

May 31 2011

Increasing number of tax information exchange agreements

Janette Pantry Soraya Jamal Over the past year, Canada has actively increased the network of jurisdictions with which it has entered into a tax information exchange agreement (TIEA). Canada has recently signed TIEAs with a number of countries, including the Bahamas, Bermuda, Cayman Islands and Jersey, and is negotiating TIEAs with other jurisdictions that do not have a double income tax treaty with Canada.

May 31 2011

Russia explains preparatory and auxiliary test

Boris Bruk and Evgeny Timofeev of Salans in Russia analyse the Bloomberg case and discover that the ruling will inspire further discussions about the framework of preparatory and auxiliary activities within the scope of the permanent establishment concept

May 31 2011

Africa’s transfer pricing commitment

A number of meetings have been held in recent months to discuss the future of transfer pricing in Africa. African governments, along with developed countries around the world, are proving their commitment to build up the transfer pricing systems in sub-Saharan Africa but a number of challenges stand in the way. Sophie Ashley builds a picture of transfer pricing today; how far has it come and how far does it need to go?

May 31 2011

Joint audits show promise of better compliance

The complexity of multinationals’ tax affairs has meant that there is a premium on tax information. This has led to initiatives aimed at increasing cooperation and coordinated action between and among tax administrations. As the tax audit landscape changes, with the beginning of joint auditing, Matthew Gilleard investigates whether two heads really are better than one.

May 31 2011

Asia directors unveil long list of concerns

After last month’s Asia Tax Executives’ Forum in Singapore, International Tax Review investigates the real issues Asian tax directors face on a daily basis as they experience greater scrutiny from authorities while at the same time finding their work being placed higher on their board’s agenda.

May 31 2011

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

Tax Executives Institute elects new president

Lluis Fargas, director tax Europe at Alcoa – the world's leading producer of primary and fabricated aluminium – has been elected president of the European chapter of the Tax Executives Institute (TEI).

May 31 2011

Netherlands: EC challenges VAT top holding companies

The European Commission (EC) is urging the Netherlands to alter its policy that allows holding companies that are not classified as entrepreneurs for value added tax (VAT) purposes to join a VAT group.

May 31 2011

Grant Thornton adds to corporate tax practice

Martin Lambert has joined Grant Thornton as a tax partner in the firm's corporate and international group.

May 31 2011

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