Treaty between Russia and UK - Russian MoF clarified whether partnerships may benefit from tax treaty provisions

On 07 February 2013, the Ministry of Finance issued Letter No. 03-08-13 clarifying whether a limited liability partnership (LLP) incorporated under the UK legislation may be considered a person for the purposes of the Russia - United Kingdom Income Tax Treaty (1994) (the Treaty). According to article 1 of the Treaty, persons who are residents […]

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India - Decision on method of valuation of shares for determining ALP for sale of shares

The Indian Income Tax Appellate Tribunal (ITAT) delivered its decision on 2 January 2013 in the case of Ascendas (India) Pvt. Ltd. v. DCIT (ITA No. 1736/Mds/2011) that the Discount Cash Flow (DFC) method is preferred over the erstwhile valuation guidelines issued by the Controller of Capital Issues (CCI) in order to determine the arm's […]

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Combating tax evasion - UK announces cooperation with the Isle of Man

On 19 February 2013, the United Kingdom and the Isle of Man agreed measures between them to combat tax evasion. The package covers both the automatic exchange of information and a disclosure facility. The disclosure facility runs from April 2013 until September 2016. Taxpayers with liabilities arising from 1999 will be given the opportunity to […]

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US Treasury Department reissues list of boycott countries that result in restriction of US tax benefits

The US Treasury Department has reissued its list of the countries that require cooperation with or participation in an international boycott as a condition of doing business. The countries listed are Iraq, Kuwait, Lebanon, Libya, Qatar, Saudi Arabia, Syria, the United Arab Emirates, and the Republic of Yemen. The list is dated 7 February 2013 […]

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US Court of Appeals dismisses US clients' class action against UBS

The US Court of Appeals for the Seventh Circuit has dismissed a class action suit filed by US taxpayers to seek damages from UBS AG (UBS) for penalties and other losses that they incurred for hiding their UBS accounts from the US Internal Revenue Service (IRS). The case involved US taxpayers who held bank accounts […]

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