http://www.internationaltaxreview.comhttp://feeds.feedburner.com/internationaltaxreview/fLlp©2019 International Tax Review60Tax DisputesTaxpayers in the cryptocurrency space worry about audits and possible disputes under limited compliance guidelines as tax authorities rush to reinforce rules and collect back taxes on cryptocurrencies.http://www.internationaltaxreview.com/Article/3889606/Tax-crackdown-on-cryptocurrencies-open-audit-and-dispute-risks.htmlMon, 19 Aug 2019 09:15:00 GMTTaxpayers are worried about tax certainty in Switzerland after the Federal Supreme Court ignored an advanced tax ruling in June. This could set a precedent for other cases.http://www.internationaltaxreview.com/Article/3883570/Absolutely-shocking-Corporates-shaken-after-Swiss-Supreme-Court-ignores-tax-ruling.htmlFri, 12 Jul 2019 10:15:00 GMTTaxpayers expect the UK to remain aligned with EU state aid rules in the event of a no-deal Brexit, but many hope any potential future amendments will not stifle investments in UK businesses or negatively impact state aid disputes.http://www.internationaltaxreview.com/Article/3877606/Taxpayers-confident-UK-will-follow-EU-state-aid-rules-in-no-deal-Brexit.htmlWed, 10 Jul 2019 09:30:00 GMTWhile most companies are moving away from aggressive tax planning, some in-house tax directors say they are still looking for new structures to reduce their effective tax rate (ETR).http://www.internationaltaxreview.com/Article/3879144/The-hunt-is-on-to-find-aggressive-structures-that-work.htmlMon, 17 Jun 2019 15:45:00 GMTData scientists and criminal investigators from the Joint Chiefs of Global Tax Enforcement initiative, or the J5, are involved in more than 50 investigations concerning sophisticated international enablers of tax evasion, including one global financial institution and its intermediaries.http://www.internationaltaxreview.com/Article/3877604/J5-cyber-tax-crime-unit-investigating-global-financial-institution.htmlWed, 05 Jun 2019 16:15:00 GMTCarlos Durán and Oriol Oliva of Uría Menéndez discuss the implications on Spanish tax regulations of the European Commission’s decision that Spain wrongly taxed the capital gains of companies resident in EFTA states.http://www.internationaltaxreview.com/Article/3876449/European-Commission-seeks-to-end-Spanish-capital-gains-tax-discrimination.htmlFri, 31 May 2019 12:00:00 GMTThe tax authorities of Indonesia, South Korea, Vietnam, the Philippines and Thailand are causing numerous problems for taxpayers as they get increasingly aggressive in their audits and focus more on transfer pricing, but companies can strategically determine which battles to fight.http://www.internationaltaxreview.com/Article/3876299/South-East-Asian-countries-get-increasingly-aggressive.htmlThu, 30 May 2019 14:15:00 GMTMultinational companies told International Tax Review how they dealt with the challenges of restructuring their intellectual property in a world of tax disputes, greater transparency and new rules.http://www.internationaltaxreview.com/Article/3875790/Survey-results-Effective-IP-management.htmlWed, 29 May 2019 10:00:00 GMTWithholding taxes represent legal obligations of monies payable to a taxing authority by a payor in Country A to a payee recipient in Country B.http://www.internationaltaxreview.com/Article/3875751/Withholding-tax-Complexity-and-inequality.htmlTue, 28 May 2019 13:00:00 GMTArvind Singal and Nitin Kapoor of RBS Services India analyse India’s move away from transfer pricing norms and the global consensus on taxing rights, and what it could mean for companies.http://www.internationaltaxreview.com/Article/3875753/Profit-attribution-to-Indian-PE-Treading-a-different-path.htmlTue, 28 May 2019 13:00:00 GMTUncertainty over how to tax offshore indirect transfers and delay to establishing an international framework for taxing such transfers is leading to a slowdown in corporate reorganisations.http://www.internationaltaxreview.com/Article/3874267/Reorganisations-slow-amid-vague-indirect-transfer-tax-regimes.htmlThu, 16 May 2019 17:00:00 GMTThe consultation period for feedback on India’s proposed changes to its profit-attribution rules has not yet ended, but the debate around the potential costs and benefits of any change is already hotting up.http://www.internationaltaxreview.com/Article/3874028/Taxpayers-say-Indias-proposed-move-to-fractional-apportionment-would-intensify-disputes.htmlWed, 15 May 2019 15:30:00 GMTCompanies such as the Daily Mail Group, Diageo and the London Stock Exchange are expecting the UK to appeal the EU’s state aid decision against the country’s CFC group financing regulation, but there is very little time to file a challenge.http://www.internationaltaxreview.com/Article/3873623/Taxpayers-caught-up-in-CFC-state-aid-ruling-expect-UK-to-appeal.htmlMon, 13 May 2019 15:30:00 GMTTaxpayers and tax authorities found a surprising amount of common ground on a panel at an ITR conference. They agreed that ‘proactive transparency’ is the surest way of avoiding messy disputes, and praised the OECD’s ICAP initiative as a means of getting tax certainty.http://www.internationaltaxreview.com/Article/3872496/Tax-authorities-and-companies-agree-its-best-to-bare-it-all.htmlFri, 03 May 2019 17:15:00 GMTTax directors are dealing with more audits, but standardising global tax operations can greatly ease the burden because it helps tax authorities understand corporate tax positions better.http://www.internationaltaxreview.com/Article/3872126/MNEs-gain-tax-certainity-through-document-standardisation.htmlFri, 03 May 2019 14:00:00 GMTTax directors have criticised a post-BEPS environment for emboldening less experienced, less technically-knowledgeable tax authorities to start transfer pricing audits based on “unsound arguments” to crack down on aggressive tax planning.http://www.internationaltaxreview.com/Article/3871718/Taxpayers-say-a-sabbatical-on-BEPS-would-be-a-good-thing.htmlWed, 01 May 2019 14:15:00 GMTTax heads expressed their frustrations with how negotiations with tax authorities often end up in negotiated settlements, and their scepticism that these same tax authorities will agree with each other on global reforms, at an ITR conference today.http://www.internationaltaxreview.com/Article/3871496/Tax-heads-The-tax-system-is-fine-its-the-day-to-day-reality-thats-the-problem.htmlTue, 30 Apr 2019 13:00:00 GMTTax professionals are concerned about a rising tax burden from adjusting profit and loss (P&L) statements after regulators axe the London inter-bank offered rate (Libor), mainly from trying to re-negotiate legacy inter-company loan contracts.http://www.internationaltaxreview.com/Article/3869543/Tax-liabilities-to-fluctuate-under-alternative-rates-after-Libor-is-phased-out.htmlWed, 17 Apr 2019 15:15:00 GMTBrazil's tax authorities may now establish liability of third parties before court judgement. Mattos Filho's Ana Paula S. Lui Barreto and Leonardo Fernandes Rebello discuss the impact to third parties and their defence.http://www.internationaltaxreview.com/Article/3869544/Brazil-addresses-the-establishment-of-joint-and-several-tax-liability.htmlWed, 17 Apr 2019 15:00:00 GMTTax leaders from Acer, H&M, Swiss Re, the Portuguese Centre for Administrative Arbitration, the Finnish and Danish tax authorities, White & Case and William Fry speak to International Tax Review about trends, predictions and what is keeping them busy ahead of the ITR Tax Disputes Summit.http://www.internationaltaxreview.com/Article/3867289/Tax-Disputes-Summit-Meet-the-speakers.htmlWed, 03 Apr 2019 10:45:00 GMTThe nominations for the 15th annual ITR European Tax Awards have been announced.http://www.internationaltaxreview.com/Article/3866261/ITR-European-Tax-Awards-2019-shortlist-announced.htmlWed, 27 Mar 2019 17:00:00 GMThttp://www.internationaltaxreview.com/Article/3862880/MNEs-take-legal-action-to-expedite-tax-returns-in-Mexico.htmlThu, 21 Mar 2019 11:30:00 GMTThe nominations for the ITR Asia Tax Awards have been announced.http://www.internationaltaxreview.com/Article/3863525/ITR-Asia-Tax-Awards-2019-shortlist-announced.htmlMon, 11 Mar 2019 11:00:00 GMTTax departments in France are increasingly agitated by the government’s efforts to impose a digital services tax (DST). This is just as the French government settles its long-running dispute with Apple.http://www.internationaltaxreview.com/Article/3857689/Tax-departments-frustrated-by-French-DST-as-France-settles-Apple-case.htmlThu, 07 Feb 2019 12:15:00 GMTThe Dutch Supreme Court has provided clarity on deductibility of acquisition and disposal costs. Kuba Grabarz and Wessel Dekker of Baker McKenzie Amsterdam explore the consequences.http://www.internationaltaxreview.com/Article/3855809/Dutch-court-rules-on-deductibility-acquisition-and-disposal-costs.htmlMon, 28 Jan 2019 13:30:00 GMTBrazil's highest court has challenged the attorney's office, shutting down an attempt to restrict taxpayers from accessing social security tax creditshttp://www.internationaltaxreview.com/Article/3852169/Brazils-Superior-Court-of-Justice-restricts-taxpayer-access-to-social-security-tax-credits.htmlThu, 03 Jan 2019 16:00:00 GMTThe June 21 decision by the US Supreme Court in South Dakota v Wayfair Inc that overturned, by a 5-4 majority, the previous leading case of Quill Corp v North Dakota has a significant effect on sales taxes within the US. But should businesses outside the US also be very concerned, given that some initial commentary suggested that this would result in a rapid change of the definition of permanent establishment?http://www.internationaltaxreview.com/Article/3849112/Taxing-rights-are-the-tax-communitys-hot-potato.htmlWed, 12 Dec 2018 16:00:00 GMTTax departments must be extra-vigilant to avoid costly litigation resulting from India’s recurrent and creative use of the general anti-avoidance rule, say tax directors – but even strong documentation may not be enough.http://www.internationaltaxreview.com/Article/3848513/Indian-GAAR-disputes-to-continue-but-there-is-hope-say-tax-directors.htmlMon, 10 Dec 2018 15:00:00 GMTInternational Tax Review’s Global Tax 20 highlights the most influential people, events and companies which have had an impact on the global tax landscape during the past year. Joe Stanley-Smith introduces the Global Tax 20.http://www.internationaltaxreview.com/Article/3847525/Global-Tax-20-2018.htmlWed, 05 Dec 2018 14:00:00 GMTThe Canadian firm Bennett Jones has appointed Ed Kroft, Jehad Haymour, and Deborah Toaze as partners and Sophie Virji and Eric Brown as associates to the Vancouver, Calgary and Toronto offices.http://www.internationaltaxreview.com/Article/3846389/Bennett-Jones-adds-five-to-its-tax-team.htmlWed, 28 Nov 2018 14:15:00 GMT