Australia has made changes on the taxation of trusts a year after a high court ruling found uncertainties and longstanding problems with the country’s tax law.
Week eight of the Supreme Court hearing saw the tax department begin their arguments by claiming that the sale of the share from the Cayman Islands company was nothing but an “artificial tax avoidance scheme”.
Two rulings from India have highlighted the critical importance of making a detailed functional and factual analysis for both determinations of a permanent establishment (PE) and also for correctly attributing profits to a PE.
Taxpayers need to be aware that transfer pricing joint audits are just around the corner and should begin preparing for them now, says a panel of leading experts.
Week seven of the Supreme Court hearing saw Vodafone’s counsel conclude his case by arguing that section 195 of the Income Tax Act cannot be applicable to taxpayers who do not have any presence in the country.
As Vodafone today concluded its arguments in its Supreme Court battle with the Indian authorities, here is a chance to look back at how the case has unravelled so far.
