Brazilian taxpayers involved in disputes centred on the country’s controlled foreign company (CFC) rules have been offered an amnesty if they withdraw their appeals. Law no. 12865, which was published today, establishes a special payment programme for companies willing to put an end to their CFC litigation.
Tax authorities need to follow information exchange protocol more carefully or risk having requests blocked, after the Australian Taxation Office (ATO) sought financial details about two Cayman Islands firms but was blocked by the UK territory’s Grand Court.
The Supreme Court of Canada has denied Envision Credit Union’s (Envision) strategy for avoiding tax upon amalgamation in a ruling which could have broader implications for the tax treatment of mergers in Canada.
Clothing retailer Grattan’s UK First-tier Tax Tribunal (FTT) defeat showed that fiscal neutrality is an aid to interpreting VAT directives, not a rule of substantive law. However, that does not mean taxpayers cannot still win with arguments based on the principle.
Item 14 of the OECD's Action Plan on base erosion and profit shifting (BEPS) aims to devise solutions to obstacles preventing countries from resolving cross-border disputes under the mutual agreement procedure (MAP). Joe Dalton investigates whether introducing mediation techniques to the MAP process is a viable solution.
