A basic transfer pricing model may be the fairest approach, says Sara Luder
The US Internal Revenue Service (IRS) and Treasury Department has released Notice 2013-43, which postpones by six months the start of withholding and account due diligence required by the foreign account tax compliance provisions (FATCA) of the Hiring Incentives to Restore Employment Act of 2010.
The government has introduced amending legislation in SI 2013/1618 to change the level of penalties which may be charged for inaccurate reporting of income from 14 specified countries.
Jonathan Peacock QC and Francis Fitzpatrick consider the salient characteristics of the GAAR, the Halifax principle and DOTAS rules
At a meeting of EU finance ministers in Brussels on 9 July, Wolfgang Schaeuble, the German finance minister, called for the withdrawal of competitive tax breaks for patents in the UK and other EU countries.
The first in a series of reports examining the tax landscape in the BRIC countries. By Colin Garwood, Anthea Wong, Bernd-Uwe Stucken, Robbie Chen and Claire Xu
What’s in practitioners’ in-trays this month, with Chris Sanger, David Harkness, Christopher Groves and Daniel Lyons
The G8 summit at Lough Erne leads the month's summary from Chris Morgan
Why might an American multinational wish to migrate? Tim Sanders and Eric Sensenbrenner explain
The European Commission has indicated that there will be a delay of at least six months before the new harmonised financial transaction tax (FTT) is ready for implementation.