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  • In two decisions, the Austrian Administrative Court (Verwaltungsgerichtshof) recently qualified the use of foreign base companies as abusive tax avoidance. The Austrian companies, in both cases, channelled interest income – which would be taxable in Austria – into foreign tax exempt or privileged subsidiaries to get such income redistributed to Austria as tax-exempt dividends. According to the court no sufficient reasons other than tax reasons were provided to justify the structure.
  • US Department of Justice The conviction of a New York banking executive for tax evasion could be critical to any case that the US authorities' might take against KPMG for selling illegal tax advice, according to news reports. At the same time, FT.com reported on August 22 that the big-four accounting firm and the authorities were in the final stages of agreeing a legal settlement over the sale of tax shelters by KPMG.
  • A review of their double tax agreement was a feature of the recent economic cooperation pact between India and Singapore. The amended agreement offers some planning opportunities, explain Srinivasa Rao and Rajendra Nayak of Ernst & Young
  • After pressure from businesses, the UK government has said it may scrap a controversial anti-avoidance tax measure relating to overseas subsidiaries.
  • Source: www.vismedia.co.uk Multinational companies with operations in India have received some welcome clarification on the country's international tax rules after a Delhi tribunal delivered a decision in a tax case involving three mobile phone operators.
  • Nick DeNovio: will join Latham & Watkins'
  • A group of Mexican lawyers, all former colleagues at the full-service law firm of Ortiz, Sainz y Erreguerena, have set up their own independent tax boutique.
  • Transfer Pricing Associates, an international boutique headquartered the Netherlands, has set up operations in the US, France, Germany, Japan, Switzerland, Australasia and South Africa.
  • Jill Weise, a former New England transfer pricing leader and firm director at Deloitte in Boston, has left the firm to join CRA International.
  • The IRS has issued an audit checklist to guide IRS examiners when they audit cost-sharing arrangements (CSA). The audit checklist contains a detailed list of documents that IRS examiners should request on audit and provides extensive instructions on how examiners should approach common audit issues, such as the valuation of buy-ins and the treatment of stock options.