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Taxpayer’s role deemed intermediary due to low risk activity The Income-Tax Appellate Tribunal (ITAT) in Delhi has overruled a transfer pricing adjustment, finding the taxpayer's activity was low risk and consisted primarily of agency services. The ITAT ruled against the transfer pricing officer's (TPO) original ruling, claiming the TPO's conclusions lacked material evidence.

Double Irish arrangement and small domestic market to blame for haven status Ireland's tax system is frequently in the headlines, with numerous references made to its scope for aggressive tax planning and active role as a tax haven. The UK, on the other hand, is being applauded for its competitive structure. This leads many to question why Ireland's tax system is viewed as a haven for avoidance rather than simply competitive.

Read this month's special features on India, Brazil, Tax technology and Qatar investment

As those involved in the OECD's base erosion and profit shifting (BEPS) project reach for the halftime oranges and energy drinks, our special BEPS feature looks at the progress made to date and explores the hurdles that litter the track ahead as the bell rings to signify the last lap in this race against an ambitious timeframe to produce meaningful outcomes. The finish line is fast approaching, but while the podium, medals and bouquets are being readied, this last lap is sure to be a tough, sweaty slog to completion, and with the volume of work to be done, success could come down to a photo finish.

India should strive to ensure that its indirect tax laws are aligned with the OECD’s VAT guidelines, believe Abhishek Jain and Saurabh Agarwal of EY.

The global increase in rule-making, the pressure on taxpayers’ resources and a dwindling tax talent pool make the harmonisation and synchronisation of tax rules a priority, believes Chris Walsh of Vertex.

Algirdas Semeta has said European taxpayers should see big improvements in compliance in the coming years.

Delivering his first Budget speech today, Arun Jaitley, India’s new finance minister, pledged to maintain a stable tax environment, but disappointed multinational taxpayers by not removing rules on retrospective tax. Indeed, while the majority of the finance minister’s proposals sound business-friendly enough, taxpayers would have liked more concrete detail.

Jean-Louis Huchant, a former chief financial officer in France, explains what information and support a CFO requires from a tax director to ensure that tax considerations are taken into account, though do not dominate, business decisions.

As a result of Law 12,973 being enacted in May, the rules applicable to Brazilian corporate income taxes and taxes on gross revenues have changed. Andrea Bazzo Lauletta and Flavio Mifano, of Mattos Filho, Veiga Filho, Marrey Jr e Quiroga, analyse some of the main changes and explain the challenges and advantages presented by the reform.