In a judgment rendered on 5 October 2021 (case 2C_891/2020), the Swiss Federal Supreme Court upheld the decision by the Federal Administrative Court of 18 September 2020 (case A-7028/2018), which had found that the proceeds realized by a Swiss corporate VAT taxpayer from the resale of a position of its own stock (“treasury shares”) did…
Case law on thepurpose of transactions is starting to develop around the world. Is there a common pattern? Whether a financing structure was a “tax avoidance arrangement” under now repealed general anti-avoidance provisions of the New Zealand Income Tax Act 2004 was examined last month by the New Zealand Court of Appeal in Commissioner of…
We are glad to announce that Dr Giorgio Beretta has joined the Kluwer International Tax Blog’s team as an editor, responsible for the new section of the blog dedicated to VAT/GST and indirect taxation. Dr Beretta holds a PhD in Tax Law from LIUC University (Milan, Italy), where he defended his doctoral thesis on “European…
I am currently working on a case that involves questions of huge significance when it comes to related-party transactions and customs valuation. It is always good to begin with a caveat and I have two. The first is that the import in question pertains to the years 2002-2006, when the Indian custom valuation rules were…
