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  • Melissa Lim As a result of and consistent with increased international cooperation via G20/OECD actions in 2015, Australia's 2016 tax landscape will be dominated by a focus on combating perceived or actual multinational tax avoidance. The biggest impact will be on 'significant global entities', that is, those with an annual global income of A$1 billion or more.
  • Christiana Nicolaou As the need for tax efficient structures has been magnified with the recent global economic downturn and the increased scrutiny from tax authorities worldwide, companies need to carefully select the jurisdiction they use for implementing such structures, while also being very careful about substance, so as to be able to mitigate any risks and taxes.
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    The government has released proposals for public comments in which it has set out the manner in which exemptions and deductions will be phased out.
  • Pierre Jean Estagerie Xavier Martinez Aldariz Does Luxembourg need tax amnesty? As with any country that applies a certain level of tax pressure on capital and work income, there are several reasons why taxpayers might omit the declaration of part of their income.
  • Tim Stewart The Court of Appeal has ruled in favour of the taxpayer in Commissioner of Inland Revenue v Diamond, concluding that the taxpayer was not resident in New Zealand for tax purposes. The Court dismissed Inland Revenue's appeal against the High Court Judge's decision, and rejected Inland Revenue's argument that Diamond's New Zealand residential investment property was a "permanent place of abode".
  • Rolf Saastad Wensing Li In a ruling from November 12 2015 (Herkules), the Norwegian Supreme Court stated that carried interest for tax purposes is to be treated as operational income in the general partner, rather than income of employment, which was the tax authorities' view. Hence, the tax authorities' view that the carried interest should be treated as personal income taxed at approximately 50% was overruled by the court. The court emphasised that the basis for an assessment of income classification and income allocation for tax purposes is primarily the agreements entered into by the taxpayers, to the extent they reflect the realities and are mutually binding.
  • Rafael Calvo Juan Salvador Pastoriza On December 17, the European General Court (EGC – a constituent court of the ECJ) handed down a judgment on joined cases T-515/13, Spain / Commission, and T-719/13, Lico Leasing, SA and Pequeños y Medianos Astilleros Sociedad de Reconversión, SA / Commission. That judgment overturned the Commission's decision on a proceeding finding that the Spanish tax lease system (STLS) constituted illegal state aid, because the EGC considered that the measures composing that system do not constitute a selective advantage.
  • Switzerland has strict e-invoicing rules. However, thanks to the principle of free consideration of evidence (contained in article 81 (3) of the Swiss VAT Law), the strict e-invoicing rules which require that all VAT relevant e-invoices are digitally signed by one of the four Swiss-admitted digital signature providers can be met with other methods of comparable quality.
  • Nadiya Omelchuk On November 30 2015, the Ministry of Finance published a draft Law which includes proposed amendments to the country's tax code. The draft Law was also submitted to the Parliament.
  • Igor Vujasinovic On October 22 2015, the National Assembly of the Republic of Srpska adopted amendments to the Law on Property Tax. The Law entered into force on January 1 2016.
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