Tax Controversy & Dispute Resolution
These newsletters provide analysis on significant tax controversy issues and related developments from around the world.
Current issue
Previous issues
June 2013
- Czech Republic: legislative update on low value adding services, tax office restructuring and recent developments in APAs
- India: CBDT published comprehensive Guidance Note and FAQs on procedural aspects regarding the Unilateral, Bilateral or Multilateral APA applications
May 2013
- OECD releases revised section on safe harbours
- More countries adopt and update GAARs to fight base erosion and profit shifting
- OECD - Draft Handbook on Transfer Pricing Risk Assessment released
- Argentine National Tax Court rejects tax authorities' position on economic relationship
- Australia: Federal Budget has multinationals in its sights
- Announcement highlights Germany's desire to pursue mandatory binding arbitration provisions in double taxation agreements
- Japan-US APA relationship - a fresh look
- Australia: Draft determination released on non-deductibility of support payments
- US-10 hotspots shaping the tax audit and controversy landscape
March 2013
- Italy: Statistics show APA programme gathering momentum and finding increasing acceptance
- US: IRS annual APA report shows dramatic increase in productivity, record number of APAs concluded
- Canada: Court upholds foreign documents request in transfer pricing audit
- U.S. Competent Authority statistics: reveal high level of double tax relief, but faster processing times, but jump in U.S.-initiated tp cases
- Germany: Fed Tax Court rules on Article 9 of the OECD Model Tax Agreement
February 2013
- Japan National Tax Agency transfer pricing update – Update on audit procedures
- Greece: New tax law in Greece amends existing transfer pricing framework and introduces a new APA program
- Australia: New TP Rules Introduced into Parliament
- Australia:Tax audit and controversy trends and key issues
- Hong Kong-Insights from first case accepted into Hong Kong’s APA process
January 2013
- U.S.- Japan tax treaty protocol to introduce mandatory arbitration
- India - Special bench ruling on marketing intangibles in case of LG Electronics India Pvt. Ltd.
- Belgium - Shifting gears towards transfer pricing audits
- Update on India General Anti Avoidance Rules (GAAR)
- Canadian tax authorities issue 2012 annual report on the Advance Pricing Arrangement (APA) program
November 2012
- Ireland releases details of a new Transfer Pricing Compliance Review programme
- Canadian tax authorities issue 2012 annual report on the Canadian Mutual Agreement Procedure (MAP) program
- Russia's tax audit and controversy landscape: What's happening now and on the horizon?
- Nigeria releases transfer pricing regulations
- Australia - Discussion Paper on review of tax arrangements applying to permanent establishments released by the Board of Taxation
October 2012
- Australia - Terms of reference released for Inspector-General review of ATO transfer pricing practices
- Supreme Court of Canada releases decision in GlaxoSmithKline transfer pricing case
- Australia - Inspector-General of Taxation announces review of transfer pricing in 2012-13
- UN releases new and updated chapters of its Practical Manual on Transfer Pricing for Developing Countries
September 2012
- India - Arm’s length price for sourcing services - cost based remuneration model adjudged most appropriate for limited risk procurement support service provider
- Brazilian Government launches system to monitor cross-border transactions involving services and intangibles - SISCOSERV
- Advance Pricing Agreement rules notified in India
August 2012
- Australia: Retrospective transfer pricing law passed by Parliament
- Indian Committee on safe harbour constituted
- Chinese tax authorities’ latest focus – Equity transfer and valuation for taxation purposes
- Canadian Supreme Court to rule on a longstanding area of controversy
July 2012
- Korea's transfer pricing and customs harmonization procedure comes into effect
- Will your Chinese affiliate be subject to certain tax authority surveys and audits in 2012?
June 2012
- Recent tax controversy reforms in Spain may result in both benefits and burdens for taxpayers
- General anti-avoidance rules: What are the key elements to a balanced approach?
May 2012
- Canada: CRA policy on access to audit reports - Informal disclosure should be the norm, not the exception
- Canada: Competent Authority - Protect your rights
February 2012
- TCC rules in favour of Velcro Canada: Beneficial ownership for tax treaty purposes
- Learnings from the Vodafone case for China tax
- Insights into the CRA's risk assessment audit approach
- Dutch tax court finds for Dutch tax administration in captive insurance company case
January 2012
- Vietnam: Tax authorities to ramp up tax and transfer pricing audits
- Transfer pricing takes a step forward in Hong Kong with the launch of an APA program
December 2011
- IRS officials discuss transfer pricing pilot cases, joint audits, and taxpayer initiated adjustments
- New Supreme Court of Canada ruling on GAAR—Copthorne Holdings Ltd.
- Canadian tax authorities issue 2011 annual report on the Advance Pricing Arrangement (APA) program
October 2011
- Recent developments within the IRS LB&I transfer pricing program
- Australian and Japanese tax authorities agree on new streamlined APA process for certain cases
- Tax losses: OECD report highlights risk areas, detection methods, and potential increase of tax disputes
September 2011
- PRC – Current tax controversy resolution alternatives: use of administrative remedies
- Maruca makes further statements regarding the development of the new Advance Pricing Agreement and Mutual Agreement Program
- Canadian tax authorities issue 2011 annual report on the Canadian Mutual Agreement Procedure (MAP) program
Contacts
- David Swenson
- Tax controversy and dispute resolution network global leader
- Tel: +1 (202) 414 4650
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