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  • Taxpayers should beware of the knotty problems that can result from the supply of services by a non-resident to a New Zealand resident, explains Tim Stewart of Russell McVeagh.
  • Competitive tax regimes and tax-planning strategies have been increasingly in the spotlight over the past 18 months or so, and the international tax landscape is changing. Louise Kelly, tax partner at Deloitte, looks at recent tax changes and assesses how Ireland is positioned after the abolition of the infamous ‘Double Irish’.
  • Caroline Devlin, partner at Arthur Cox, explains the features of the Irish tax and legal system which make it an attractive investment location, and looks specifically at Chinese outbound investment in this regard.
  • Read this month's special features for North America and Ireland
  • Mexico has incorporated an independent public organisation – Procuraduría de la Defensa del Contribuyente (PRODECON) – which acts as a taxpayers’ ombudsman, with a mandate to guarantee and protect the constitutional and human rights of taxpayers. René Meza and César De la Parra of Chevez, Ruiz, Zamarripa y Cía outline the salient features of the dispute resolution mechanisms under PRODECON.
  • Bill Maclagan, QC, partner at Blake, Cassels & Graydon, looks at the comments of the Canada Revenue Agency (CRA) on derivative forward agreements and exchangeable share transactions, and shares insights as to what the authorities are expecting from taxpayers.
  • Larissa Neumann, partner at Fenwick & West, assesses the transfer pricing landscape in the US, looking at authority attitudes and areas of focus based on recent dispute cases, and points to the need for consensus on the transfer pricing aspects of the OECD’s project to tackle base erosion and profit shifting.
  • Eighty five jurisdictions are now signatories to the Multilateral Convention on Mutual Assistance in Tax Matters, after the Seychelles became the latest to do so today.
  • The oil industry has been questioned several times by the Brazilian tax authorities regarding agreements covering oil and natural gas exploitation services, including the prospection and concurrent charter of offshore platforms.
  • Matthew Cridland Australia was focussed on state and federal politics in early February, including an upset election result in Queensland. Notwithstanding these distractions, tax developments still continued apace. The Federal Court provided a detailed judgment regarding the tax promoter penalty provisions in FCT v Arnold (No 2). The court imposed penalties of $1.5 million in respect of a pharmaceuticals donations scheme.
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