Almost universally in 2012, it seems there has been a pledge from revenue authorities bidding to spare resources, and taxpayers craving certainty, to try and reduce the risk of entering new litigation. But while some litigation is undoubtedly avoidable, there are always those cases which climb through the judicial system, demanding attention from the highest courts. Such cases often have a dramatic impact on how taxpayers do business. Joe Dalton looks at the tax rulings multinationals need to follow in 2013.
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While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems