In a decision that could give relief to more than 20 other pending cases, the Bombay High Court has ruled in favour of Vodafone that in the absence of income, a share issue transaction cannot be subjected to transfer pricing.
Amazon has been drawn into a European Commission (EC) investigation into the tax regimes of three member states: Ireland, Luxembourg and the Netherlands. The EC has said its preliminary view on Ireland is that “the tax rulings of 1990 (effectively agreed in 1991) and of 2007 in favour of the Apple group constitute state aid”.
ANALYSIS: The US has moved to try and curb the practice of inversion transactions which has seen a handful of companies relocate overseas, with many more considering the option. The rule tightening attempts to reduce the benefits of an inversion.
Scotland yesterday voted to remain part of the UK, with 2,001,926 “No” votes versus 1,617,989 “Yes” votes in response to the question “Should Scotland be an independent country?” The rejection of independence is being celebrated by the UK tax community, as a “Yes” vote would have caused considerable turmoil for taxpayers, advisers and authorities on both sides of the border.
The OECD today unveiled its 2014 deliverables at the halfway stage of the multilateral organisation’s ambitious base erosion and profit shifting project, commissioned by the G20, which represents the biggest ever review of international tax rules.
If the existing government retains leadership after the general election, no material changes are expected from a tax perspective. But if a Labour-led government wins power, advisers warn of significant tax reforms with major implications for taxpayers.