Tax Disputes
A recent UK First-tier Tribunal decision highlights the broad application of an anti-avoidance rule to deny tax relief, say Robert Waterson and Matthew Cummings of Eversheds Sutherland
The Royal Bank of Canada’s success over HMRC represents a milestone in the interpretation of double tax treaties, Norton Rose Fulbright partner Dominic Stuttaford said
Led by international law firm Hughes Hubbard, SKAT was awarded $500 million in damages after several defendants were convicted of fraud, negligence and unjust enrichment
Patrick O’Gara, who is rated as a ‘highly regarded practitioner’ by World Tax, had spent over 20 years at Baker McKenzie
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Sponsored by DeloitteIncreased transparency requirements have pushed the management of tax risk higher up companies’ agendas. Juan Ignacio de Molina, Yoshihiro Adachi, and Carlos Serrano of Deloitte explain how corporate governance and cooperative programmes can help. -
Sponsored by DeloitteSophie Brown and Sarah Blakelock of Deloitte highlight the lessons to be learnt from transfer pricing disputes and case law as tax authorities increasingly pursue data interrogation, source data, and access to emails.
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Sponsored by DeloitteEddie Morris of Deloitte considers the limited evidence available on the use of the arbitration clause of mutual agreement procedure articles to resolve transfer pricing disputes, and pinpoints areas for improvement.
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