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India’s top lawyer has advised his government not to appeal the Rs 3,200 crore ($525 million) Bombay High Court (HC) transfer pricing decision in favour of Vodafone.

Scotland is to gain greater tax-raising powers after the release of the Smith Commission report. But the benefits for the country will see are not as clear-cut as some may have originally thought.

Piet Battiau, head of consumption taxes at the OECD’s Centre for Tax Policy and Administration, believes the OECD is working effectively with other multilateral organisations and that common ground is being found on key indirect tax issues.

William Maclagan, QC and David Ross, of Blake, Cassels & Graydon explain why the Tax Court of Canada stopped the Canada Revenue Agency (CRA) from using evidence from litigation to support fresh reassessments against Fio Corporation.

To add your deals to our deals table, contact Joe Stanley-Smith on joseph.stanley-smith@euromoneyplc.com

The 16th edition of Transfer Pricing is available as a downloadable pdf.

A UN body has highlighted the prospects of tax harmonisation and the elimination of tax competition in Asia-Pacific as methods for helping countries in the region to increase the amount of taxes they raise.

Luis Manuel Viñuales Having overcome – or, at least, that's what Spaniards hope – the toughest economic crisis in recent Spanish history, the government has started working on a major tax reform, centred predominantly on corporate and personal income taxes. The reform is expected to come into force on January 1 2015 and, therefore, the preliminary Bills are likely to undergo changes during its passage through parliament. One of the main aspects of the corporate income tax reform which has already been published and which is unlikely to undergo much change during the legislative process is the Spanish participation exemption regime, aimed at avoiding instances of international double taxation under existing law.

Samantha Merle In a recent circular, the Luxembourg tax authorities defined the rules applicable upon request to undertakings with a share capital and accounts in the same foreign currency, which wish to determine their taxable income by simply converting their commercial result in foreign currency into EUR. The release of this circular is motivated by the fact that strict application of the Luxembourg valuation rules to these undertakings may in certain cases create artificial taxable exchange profits, which appear when preparing a tax balance sheet in EUR and thus do not reflect the economic reality. To avoid this kind of situation, the tax authorities have defined the rules and conditions to apply the foreign functional currency for tax purposes. We present the main aspects. The possibility to use the functional currency applies, upon request, to undertakings with share capital and accounts in the same foreign currency. Once an undertaking has opted for the regime, it will have to use its functional currency as long as its share capital remains denominated in this currency. A request has to be filed with the Luxembourg tax authorities at the latest three months before the end of the tax year in which the undertaking intends to benefit from the regime (September 30 at the latest, if the tax year corresponds to the calendar year).

Giuliano Foglia