Tax News Slaughter and May

What does the recent trend of criminalisation of transfer pricing matters in France mean for businesses operating in the country? What tools are tax authorities in France using to obtain information and to enforce the rules? What action can be taken to minimise French transfer pricing risk and what options are available to resolve disputes?
Julien Gayral, Partner at Bredin Prat, joined Charles Osborne and Zoe Andrews to discuss these questions and more.
This is the final episode in a series on tax disputes risks. In addition to France, the series covers Brazil, the USA, Australia, India and Nigeria.

How do Nigerian tax disputes generally proceed? Should taxpayers continue to comply with the transfer pricing regulations although their validity is in question? How are plans for a tax amnesty likely to develop?
Lolade Ososami, Partner at Udo Udoma & Belo-Osagie, joined Sarah Osprey and Tanja Velling to discuss these questions and more.
This is the fifth of six episodes in a series on tax disputes risks. In addition to Nigeria, the series covers Brazil, the USA, Australia, India and France. Episodes are released weekly. Subscribe to the Tax News show to be notified of new episodes.

Why is India's tax disputes landscape unique? How should taxpayers best approach dealings with the Indian tax authority? What is the impact on taxpayers of the recent case concerning the most favoured nation clause in Indian tax treaties, including for multinationals taking dividends out of India?
Mukesh Butani, Founder and Managing Partner of BMR Legal Advocates, spoke with Sarah Osprey, Partner in Slaughter and May’s Tax Practice, and Zoe Andrews, Head of Tax Knowledge at Slaughter and May, to answer these questions and more.
This is the fourth of six episodes in a series on tax disputes risks. In addition to India, the series covers Brazil, the USA, Australia, Nigeria and France. Episodes are released weekly. Subscribe to the Tax News show to be notified of new episodes.

In this podcast, Zoe Andrews and Tanja Velling discuss two Court of Appeal decisions on the loan relationships unallowable purpose rule in section 441 of the Corporation Tax Act 2009: BlackRock and Kwik-Fit. In both cases, the Court of Appeal confirmed the Upper Tribunal’s decision that there was an unallowable tax avoidance purpose. In BlackRock, this led to a complete disallowance of all interest deductions whereas, in Kwik-Fit, the deductions could be partly attributed to the taxpayers’ commercial purpose and consequently allowed. The podcast draws out key lessons.
Zoe and Tanja also discuss the Court of Appeal’s welcome clarification, in Hargreaves Property Holdings, that the exemption from withholding tax for interest to which a UK-resident company is beneficially entitled is not automatically lost merely because the company on-pays the interest. The podcast further covers changes to HMRC guidance, including on the exemption from the 1.5% stamp taxes charge, clearances in respect of the purpose test in the capital gains tax reorganisation rules and the post-Brexit interpretation of VAT and excise law, as well as international tax developments at the OECD and UN.

What is the Australian Taxation Office’s approach to tax compliance for multinationals? Does the ATO take into account a wider range of factors than HMRC when considering a settlement? What does the PepsiCo decision mean for the ATO’s expansive definition of “royalties”?
Angela Wood, National Practice Group Leader of Clayton Utz Tax Practice, joins Richard Jeens, Co-Head of Slaughter and May’s Tax Disputes Practice, and Tanja Velling, Tax PSL Counsel at Slaughter and May, discuss these questions and more.
This is the third of six episodes in a series on tax disputes risks, their prevention and resolution. In addition to Australia, the series covers Brazil, the USA, India, Nigeria and France. Episodes are released weekly. Subscribe to the Tax News show to be notified of new episodes.

What are current trends in US tax disputes? How can you reduce litigation risk? What is the Supreme Court likely to make of Moore, a case that could call into question large swathes of the US tax system? 
Clark Armitage, Transfer Pricing Advisor and Member at Caplin & Drysdale, joins Dominic Robertson, Co-Head of Slaughter and May’s Tax Disputes Practice, and Tanja Velling, Tax PSL Counsel at Slaughter and May, to delve into these questions and more.
This is the second of six episodes in a series on tax disputes risks, their prevention and resolution. In addition to the USA, the series covers Brazil, Australia, India, Nigeria and France. Episodes are released weekly. Subscribe to the Tax News show to be notified of new episodes.