US Tax Court denies Coca-Cola’s request to reconsider 2020 decision Coca-Cola is stuck with a hefty tax bill after the US Tax Court rejected its bid to file an out of time motion. The company hoped the Tax Court would reconsider its 2020 decision. By Josh White December 02 2021
DAC6 in Portugal: Thinking ahead Ricardo Seabra Moura and Miguel Teles of Morais Leitão explain why it is important that parties involved in cross-border arrangements understand the role that economic substance plays as a result of DAC6 reporting. By Miguel Teles & Ricardo Seabra Moura October 26 2021
Australia’s response to Glencore, legal professional privilege and the CCIV regime Jun Au of DLA Piper Australia provides an overview of tax developments in Australia including the ATO’s response to the Glencore decision, improvements to the corporate collective investment vehicle regime and legal p... By Jun Au October 26 2021
Limitations on the application of tax incentives in Portugal Francisca Marabuto Tavares of Morais Leitão explains why tax incentives in Portugal maybe discouraging for many companies. By Francisca Marabuto Tavares September 23 2021
Norway: Supreme Court judgment on the interpretation of the ‘offshore’ clause and the t... Anette Fjeld and Lene Bergersen of Deloitte Norway explain the Norwegian Supreme Court judgment in the case between six sea workers and Poseidon Personnel Services SA on one side and the Norwegian state on the other s... By Anette Fjeld & Lene Bergersen September 03 2021
Is your tax department game ready? - EY's Asia-Pacific guide 2021 launched In collaboration with EY, ITR brings you the key themes that tax departments in the Asia-Pacific region and beyond should consider as they prepare for the tax world of tomorrow. By Prin Shasiharan August 12 2021
Portugal’s Tax and Customs Authority looks to avoid problematic trial and error model Pedro Cruz Gonçalves of Morais Leitão discusses why the PTA's inspections often embodies a model that a modern administration should not adopt. By Pedro Cruz Gonçalves August 02 2021
Depreciation on goodwill: Final nail on the coffin by the Indian tax authorities? S Vasudevan and Karanjot Singh Khurana of Lakshmikumaran & Sridharan explain why changes to the recording of goodwill will have far-reaching consequences on business acquisitions and reorganisations. By Karanjot Singh Khurana & S Vasudevan July 28 2021
Tax arbitration system goes live in Cape Verde Sérgio Vasques of Lobo Vasques explains why Cape Verde’s new tax arbitration system is a major stepping-stone to boost the country's competitiveness. By Sérgio Vasques July 26 2021
How will the G20/OECD’s pillar one and pillar two project affect disputes? Alison Lobb and Howard Osawa of Deloitte explore potential areas of controversy arising from the G20/OECD’s pillar one and pillar two project and considerations to manage disputes and potential double taxation. By Alison Lobb & Howard Osawa July 20 2021
Deloitte’s 2021 survey on the global TP controversy landscape Vrajesh Dutia and Ananthanarayanan R of Deloitte analyse the results of a TP controversy survey, involving TP practitioners across the globe, which seeks to gain a better understanding of the ever-evolving TP landscape. By Ananthanarayanan R & Vrajesh Dutia July 20 2021
