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Singapore court overturns accepted practice on taxation of swap payments

Sundareswara Sharma of ATMD Bird & Bird explains the Singapore Supreme Court decision that swap payments under aircraft leasing arrangements to non-resident special purpose companies are not deemed to be derived from Singapore, and that such payments are not subject to withholding tax.

November 19 2010
Indian speakers call for improved dispute resolution panels

A lack of accountability of officials is one of the reasons why India is struggling to develop an effective form of dispute resolution system for tax cases, delegates at International Tax Review's first India Tax Forum were told.

Ralph Cunningham, November 18 2010
Withholding tax in El Salvador declared “soak-up” by IRS

The Internal Revenue Service (IRS) has strongly suggested that US financial institutions with operations in El Salvador re-evaluate their tax position in El Salvador.

November 18 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 18 2010
McCullough leaves for Blake Dawson

Peter McCullough has joined Blake Dawson as a partner in its direct tax practice in Sydney.

November 18 2010
St. Michael Trust Corp v The Queen

Garron, St. Michael, trust, residency

November 17 2010
BAT fails to convince Full Federal Court on capital gains

The Full Federal Court of Australia has dismissed an appeal by British American Tobacco (BAT) in a A$89 ($87 million) million capital gains tax dispute.

Salman Shaheen, November 17 2010
Task force proposes national sales tax to tackle runaway US debt

On November 17 the Bipartisan Policy Centre’s Debt Reduction Task Force released its anticipated plan to reduce US debt.

November 17 2010
Thailand loses cigarette tax case before WTO

On November 15 the World Trade Organisation (WTO) Dispute Settlement Body ruled against Thailand in a trade dispute about the country’s domestic tax laws.

November 17 2010
CIOT launches transfer pricing examination

The Chartered Institute of Taxation (CIOT) is launching a transfer pricing option examination paper as a global benchmark of quality and achievement and an independent means of demonstrating transfer pricing expertise.

November 17 2010

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