ITR Search | International Tax Review

Tax disputes winners prove their worth at Asia Awards

Baker & McKenzie was rewarded for its expertise in dispute resolution throughout the region when it won International Tax Review’s Asia Tax Disputes Firm of the Year award in Singapore on Tuesday night.

November 25 2010

Foster’s prepares to challenge ATO claim

Foster’s is facing up to a confrontation with the Australian tax authorities after it announced yesterday that it does not accept an official assessment that it owes almost A$66 million ($65 million) in tax and interest arising from a capital loss in the 2004 financial year.

November 25 2010

India's rulings body gets new chief

Justice Balasubramanyan has been appointed as chairman of the Authority for Advance Rulings in India, which is aimed at avoiding disputes between taxpayers and tax authorities, and bringing certainty of about the amount of a taxpayer's income tax liability.

November 24 2010

US Tax Court and IRS at odds over transfer pricing in Veritas

The IRS’ Action on Decision (AOD), on November 10 2010, stating it does not agree with the result or reasoning of the US Tax Court’s decision in Veritas Software Corp. v. Commissioner, brought a spectrum of transfer pricing conflicts to light as the US Tax Court and IRS struggle to find common ground.

November 24 2010

ITAT ruling on the transfer pricing aspects of management services fees

The Bangalore Income Tax Appellate Tribunal (ITAT) has ruled in favour of the Commissioner of Income Tax in the case of Gemplus India Pvt.

November 24 2010

Honduras to introduce transfer pricing rules

Honduras is preparing new legislation to combat tax evasion, including a chapter on transfer pricing, as part of its fiscal reform.

November 24 2010

Transfer pricing inspections do not focus on services

Cristiane Magalhães and Angélica Santos Torres of Machado Associados examine the changing situation in Brazilian transfer pricing

November 24 2010

Venezuela transfer pricing authorities flex their muscles

Venezuelan tax authorities have penalised 68 taxpayers that failed to comply with the country’s transfer pricing rules.

November 24 2010

Lack of thin capitalisation rule gives taxpayer victory in India

The Income Tax Appellate Tribunal (ITAT) has held that tax planning carried out within the provisions of the law cannot be classed as a structured transaction for tax evasion purposes, even if the structure saves the company tax.

November 24 2010

How India looks at the tax characterisation of computer software transactions

The characterisation of computer software transactions can be regarded as one of the most controversial issues in international taxation, believes Srinivasa Rao of Ernst & Young in India.

November 23 2010

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