A measure introduced by China’s State Administration of Taxation (SAT) to help taxpayers invoke the mutual agreement procedure (MAP) for the resolution of cross-border tax disputes took effect on Friday.
Joe Dalton reviews the key court cases in major jurisdictions that will impact multinationals next year, analysing the potential implications of the judgments for international tax planning.
The doctrine of legitimate expectation arises in UK disputes where HM Revenue & Customs (HMRC) has reversed its position on a ruling issued to a taxpayer to the detriment of the taxpayer. At a seminar hosted by PwC Legal in London on Monday, Sam Grodzinski QC, of Blackstone Chambers, highlighted the issue and explained how taxpayers should assess when a legitimate expectation argument will succeed.
Transfer pricing specialists at Standard Chartered, Citigroup and Nomura Securities expect the OECD’s base erosion and profit shifting (BEPS) project to have a significant impact for financial institutions but worry that new transfer pricing rules will be burdensome in what is already a highly regulated sector.
Taxpayers at International Tax Review’s Global Transfer Pricing Forum 2013 said they are already taking steps to ready themselves for the implementation of new tax rules and revenue authority approaches before the implementation of the OECD’s base erosion and profit shifting (BEPS) measures.
Taxpayers at International Tax Review’s Global Transfer Pricing Forum in Singapore reviewed the pros and cons of India’s new advance pricing agreement programme (APA), raising some concern over one of the features of the process - mandatory site visits from revenue officials.
