Corporate Tax and Tax Controversy Law Guide
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About the Practice Guide
Editor
Miller Thomson is a national business law firm with approximately 500 lawyers across five provinces in Canada — the broadest reach of any Canadian law firm. Partnering with clients across Canada and internationally, we bring deep local insight to a comprehensive range of business law, litigation and dispute services as well as other specialized practices. We focus on understanding your business, your industry, and the factors that drive long-term growth and success. Learn more at millerthomson.com or follow us on LinkedIn.
Read more →Jurisdictions
AUS
Australia
Austria
AUT
Austria
Brazil
BRA
Brazil
Canada
CAN
Canada
China
CHN
China
Denmark
DNK
Denmark
Germany
DEU
Germany
Ghana
GHA
Ghana
Hungary
HUN
Hungary
Iceland
ISL
Iceland
India
IND
India
Ireland
IRL
Ireland
Italy
ITA
Italy
Jamaica
JAM
Jamaica
Malta
MLT
Malta
Mauritius
MUS
Mauritius
Nigeria
NGA
Nigeria
Norway
NOR
Norway
Portugal
PRT
Portugal
Spain
ESP
Spain
Sweden
SWE
Sweden
Switzerland
CHE
Switzerland
Uganda
UGA
Uganda
UK
GBR
United Kingdom
US
USA
United States
Uruguay
URY
Uruguay
BGR
Bulgaria - Market Insights
Denmark
DNK
Denmark - Market Insights
Jamaica
JAM
Jamaica - Market Insights
Kenya
KEN
Kenya - Market Insights
Malta
MLT
Malta - Market Insights
Nigeria
NGA
Nigeria - Market Insights
Norway
NOR
Norway - Market Insights
Sweden
SWE
Sweden - Market Insights
Switzerland
CHE
Switzerland - Market Insights
UK
GBR
United Kingdom - Market Insights
Introduction
Editor’s Introduction
It comes as no surprise that Western governments are struggling to figure out how to pay for services that their prospective populations demand. Those nations that fall outside the Western orbit face a similar challenge of maintaining societal order and that requires, inter alia, money, which in turn provides power. One of the key ways to achieve societal order and harmony is by imposing and collecting taxes from the populace. Put another way, it is taxes that, in part, pay for social and economic programs and the maintenance of societal harmony.
In this guide, you will find a useful and focused, country-by-country examination of the key corporate tax and tax controversy issues. This is the starting point for any thoughtful approach to the subjects. From here, it is up to the reader to connect with the leading law firms and experts that contributed to either the question-and-answer section, market insights or both in this work.
From a review of the country-by-country analysis, certain general themes run true. Past governmental approaches to corporate taxation are no longer in fashion. Older tax planning tactics — such as treaty shopping, profit shifting and the utilization of low tax jurisdiction arbitrage — have become far less prevalent. In today’s environment, law firms around the globe are dealing with tougher rules of enforcement requiring greater, if not complete, transparency. Some of these developments can be traced to initiatives such as the OECD Pillar Two policy, which imposes a 15% minimum effective tax rate on large multinationals. Enforcement has taken centre stage in relation to transfer pricing audits, particularly, and the taxation challenges posed by the digital economy. The growing focus on the concept of permanent establishment, and the broadening of its scope, has further expanded audits by revenue authorities. Few revenue authorities have failed to expand the application of the General Anti-Avoidance Rule (GAAR) as governments around the world broaden domestic anti-avoidance rules. These themes all lead to a conclusion that taxation, with all of its complexities, requires firms and individuals that are truly devoted to the study of tax and understanding of the related law. The contributors to this work possess those essential skills, and I am sure that you, the reader, will discover this to be true.
Acknowledgement
A book of this nature and scope would not be possible without the commitment and assistance of many people. It is always a challenge to single out a few without possibly offending someone who may feel “left out”. But, then again, there are always a few people that are instrumental in leading to the success of this type of project. So, I begin by thanking and acknowledging my former law partner, Ron Choudhury. Ron is a first-rate tax planner and, with his input, we developed the question-and-answer section for corporate tax. Thank you Ron! I am indebted to Katie Burrington of Global Legal Post. It was our previous experience of working together that got me excited about this project and on board as the editor. Thank you, Katie! There is a host of people that are part of the Global Legal Post team, and two further standouts are Emily Kyriacou and Debbie Knowles. Emily is in charge of commercial projects. I have been fortunate to have worked with Emily before — a polished professional with a great sense of humility and humour. Debbie has been indispensable as the editorial and production manager. Without her skills and guidance, this book would never have made it to print!
The Canadian chapter would not have been possible without the work of one of our firm’s finest tax associates, Raffaella Garofalo. Thank you, Raffaella! And I can hardly forget to thank my assistant, Jacob Bourque. Jacob has managed to keep the paper flowing and me “out of trouble”.
Finally, I want to thank our contributors because without their commitment and work this book and project would not have been possible. Thank you contributors!
Contributors
ALN Kenya | Anjarwalla & Khanna is East Africa’s largest full-service law firm and founder of ALN, an award-winning alliance of 16 leading full-service law firms across anglophone and francophone...
BBA//Fjeldco is leading in the field of mergers and acquisitions, capital markets, banking and corporate finance, energy and PFI projects, as well as general corporate and commercial matters. We have...
Bergstein Abogados combines the expertise of nearly 70 years with the dynamism and energy of a group of young professionals who form the firm today. The talent, dedication, and expertise of its lawyer...
Birungyi, Barata & Associates (BBA) was founded in 2003 and has since established itself as the leading tax law firm in Uganda, aiming to provide professional and efficient tax and legal services...
CMS Prism in association with CMS specialises in all aspects of revenue law, including tax advisory, transactional tax, and tax controversy matters, with a significant cross-border element. It represe...
Chiomenti is a leading independent Italian law firm providing integrated legal and tax advice to corporations, financial institutions, investors and high-net-worth individuals. Founded in 1948, the fi...
Cuatrecasas is an international law firm with a strong presence in Spain, Portugal and Latin America, where it has offices in Chile, Colombia, Mexico and Peru. With a diverse multidisciplinary team of...
Deloitte Malta is a multidisciplinary firm that offers a wide range of services. The firm provides a broad range of leading professional services to select clients. It serves large international and d...
Demarest Advogados is one of Brazil’s and Latin America’s most respected law firms, with over 75 years of experience. It provides full-service legal advice, combining technical quality, integrated pra...
Djingov, Gouginski, Kyutchukov & Velichkov's tax team is revered in the market for its formidable non-contentious tax practice. The team acts for a wide range of clients in the technology and logi...
G Elias is a leading Nigerian business law firm founded in 1994, with offices in Lagos and Abuja. For over 30 years, the firm has maintained a strong international outlook, delivering innovative, high...
Greenberg Traurig is a large, multinational law firm founded in Miami, Florida in 1967. It is one of the largest law firms in the United States by headcount, and it has over 3200 attorneys operating a...
With approximately 450 lawyers, tax advisors, and notaries providing legal services across eight offices in Germany, HEUKING is one of the leading commercial law firms in Germany. HEUKING provides leg...
Drawing from more than 25 years of Asian legal expertise and Western commercial experience, our law firm has full-time, dedicated and professional teams based in China and Singapore. Over the yea...
Hamilton Locke is a corporate and commercial law firm focused on evolving the traditional approach to legal services. With a team of over 70 partners and 200 lawyers across the Tasman, we provide exce...
LFB Legal is a Hungarian boutique law firm established in 2018, focused on dispute resolution and tax. The main focus of the team is tax audit and tax disputes. We manage tax audits for clients in var...
Lakshmikumaran & Sridharan has been a leading law firm in India since 1985. With 14 offices and over 400 professionals specialising in corporate and commercial laws, dispute resolution, taxation,...
Miller Thomson is a national business law firm with approximately 500 lawyers across five provinces in Canada — the broadest reach of any Canadian law firm. Partnering with clients across Canada and i...
Papilio Services Limited has been operating in Malta since 2012, specialising in a comprehensive suite of services that encompass corporate advisory, tax optimisation, compliance assurance, and reside...
Patterson Mair Hamilton (PMH) is a full-service law firm delivering comprehensive corporate and commercial legal expertise to help clients achieve their business objectives. PMH’s approach is built on...
With an uncompromising dedication to professional expertise, business understanding and client service, Schjødt aims to be the first choice when the stakes are high and important values are in play. W...
Sullivan & Cromwell provides the highest quality legal advice and representation to clients worldwide. The firm’s record of success and unparalleled client service has set it apart for more than 1...
Tax Partner AG focuses on Swiss and international tax law and is recognised as a leading independent tax boutique, advising multinational and national corporate clients as well as individuals in all t...
TEMPLARS is a leading commercial law firm with 4 offices across Nigeria and Ghana( Lagos, Abuja, Port Harcourt, and Accra), providing full-service legal support across West Africa .The firm advises on...
With over 300 lawyers, tax experts, notaries and counsels, Walder Wyss is one of Switzerland’s leading law firms. We operate from six fully integrated offices in Switzerland, ensuring seamless co...
White & Case is a leading global law firm with offices in over 30 countries. The firm is particularly renowned for its international reach and cross-border transactional expertise. It advises on a...
William Fry is a leading Irish corporate law firm, with over 350 legal and tax professionals and over 500 staff. The firm is ranked by international directories as being a leader in its core practice...
Wolf Theiss is one of the leading law firms in Central, Eastern and South-Eastern Europe (CEE/SEE). The firm opened its first office in Vienna over 60 years ago and now brings together over 400 lawyer...
