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  • The past month saw Starbucks hit the headlines again, with Margrethe Vestager, European Competition Commissioner, ordering the Netherlands to claw back revenue from the coffee company after her unit decided the tax ruling agreed by the two constituted unlawful state aid. Vestager said she hopes "this message will be heard by member state governments and companies alike", so her tax ruling enquiries are unlikely to end there.
  • To start his new monthly column, Ralph Cunningham, the Hong Kong-based managing editor of International Tax Review, argues that capacity building will be critical to BEPS implementation in the Asia-Pacific region if piecemeal, unilateral measures are to be avoided.
  • The Federal Court in Australia has ruled that Chevron Australia did not prove the interest rate on a loan to its US partner company was at arm’s-length. Chevron now owes the ATO AUS $300 million ($213 million).
  • Companies in certain types of VAT groups in Hungary will have to pay higher VAT bills as a result of the European Court of Justice (ECJ) Skandia ruling, and could also face intensified VAT audits, as the country has finally started to implement the ruling.
  • Her Majesty’s Revenue and Custom’s (HMRC) annual study into the size of the UK tax gap has revealed a drop in figures, indicating that compliance levels concerning multinationals have improved.
  • The Irish Finance Bill published on October 22 2015 contains details of Ireland's response to Action 13 of BEPS - the minimum standard of country-by-country reporting (CbCR).
  • Jim Fuller David Forst Revenue Ruling 91-32 holds that a foreign partner's gain from the sale or exchange of an interest in a partnership that conducts business in the US through a fixed place of business is effectively connected with the US business. The gain is so treated to the extent of the appreciation in value of the partnership's "effectively connected" assets, which involves a ratio approach. In the case of a treaty, the gain is treated as effectively connected to gain attributable to a US permanent establishment.
  • Hans Rudolf Habermacher Raoul Stocker Switzerland plans to implement the country-by-country reporting (CbCR) and exchange of information provisions recommended by the OECD as part of its final package of measures to counter tax base erosion and profit shifting (BEPS).
  • Abigail Blanco The 2015 corporate income tax reform package has made considerable changes to the rules on companies that can be consolidated. Many of these stem from the European Court of Justice (ECJ) judgment dated June 12 2014, on joined cases C39/13 to C41/13.
  • Guilherme Costa The Turkish tax authorities have demonstrated over the last few years that there is no time to lose in the implementation of their ambitious electronic transformation plan.