This week in tax: Tax disputes for Samsung and Rio Tinto Tax controversy matters have dominated this week’s tax news with another dispute beckoning for mining corporation Rio Tinto in Australia, while Samsung and Ericsson celebrate a ‘temporary’ win in the Indian Supreme Co... By Anjana Haines March 05 2021
ATO wins legal professional privilege dispute and sets new COVID-19 PE risk guidance From judicial decisions to ATO guidance updates, Paul McNab of DLA Piper summarises the tax-related developments from early 2021 in Australia. By Paul McNab February 24 2021
Facing the challenges of reform – ITR's Switzerland Special Focus launched As Switzerland tackles a range of novel fiscal challenges, ITR has partnered with leading tax advisors to prepare you for the tax implications of the year ahead. By Prin Shasiharan February 11 2021
Top 50 most-read ITR Expert Analysis articles of 2020 The main themes that emerged from the most-read articles were COVID-19, industry specific articles, tax reform, transfer pricing and DAC6. By Prin Shasiharan February 05 2021
Preserving taxpayers’ rights in China Kevin Ng, Ron Cheng Ma and Kerry Yanbin Kuang of Deloitte explore how China has strategically developed its legal framework to provide a higher level of protection for taxpayers. By Kerry Yanbin Kuang & Kevin Ng & Ron Cheng Ma February 05 2021
Conseil d’Etat recharacterises the existence of a PE in the digital economy Nicolas Duboille and Hugo Levit of Sumerson analyse why the judges overturned the decision of the Paris Administrative Court of Appeal and ruled in favour of a broad interpretation of ‘dependent agent’. By Hugo Levit & Nicolas Duboille February 02 2021
Italy amends regulation of advance rulings Federico Vincenti and Alessandro Valente of Crowe Valente / Valente Associati GEB Partners outline the principal changes to advance tax rulings, as set out in the Italian budget law for 2021. By Alessandro Valente & Federico Vincenti February 02 2021
OECD explores dispute resolution improvements Mark Martin and Thomas Bettge of KPMG in the US describe the OECD’s recent proposals for strengthening the Action 14 minimum standard, and explore how adopting these proposals could improve dispute resolution. By Mark Martin & Thomas Bettge January 28 2021
Brazilian electricity distributors obtain victory at the Supreme Court Carolina Romanini Miguel and Gabriel Caldiron Rezende of Machado Associados discuss the decision of the Brazilian Federal Supreme Court, which deemed the tax liability of energy distributors on free market transaction... By Carolina Romanini Miguel & Gabriel Caldiron Rezende January 27 2021
France: Twin cases reduce the scope of taxing capital gains on sale of French shares Nicolas Duboille and Alexia Dal Ponte of Sumerson analyse recent case law concerning the application of the French capital gain tax applicable to non-resident entities on the transfer of a significant shareholding in ... By Alexia Dal Ponte & Nicolas Duboille January 25 2021
China strengthens litigation framework through increased use of APAs and MAPs Xiaoyue Wang and Choon Beng Teoh of KPMG China explain how recent developments affirm the programmes’ effectiveness in providing certainty to transfer pricing arrangements in China. By Choon Beng Teoh & Xiaoyue Wang January 20 2021
