Bank of Nova Scotia sought to carry back a non-capital loss to offset a transfer pricing adjustment arising from a settlement with Canadian tax authorities. The dispute concerned whether interest on the carryback should run from the date of the written request or the original return filing date. Canada's Tax Court dismissed the appeal in 2021, ruling the deemed payment date was 30 days after the written request, consistent with the unambiguous statutory wording ... Read more

Telefónica challenged the application of late payment interest on income tax debts for 2000 and 2001, arguing that interest accumulating beyond statutory resolution deadlines was disproportionate. Peru's Constitutional Court agreed, finding that excessive delays without valid justification violated taxpayers' rights, and ordered SUNAT to recalculate the default interest excluding amounts accrued beyond the legal time limits set for resolving the dispute ... Read more

Apple has agreed to paid an additional 571 million euros to France in a settlement with the tax authorities. According to the French news agency, l’expansion l’Express – “For several months now, secret negotiations on this subject have been taking place between Apple and the French International Audit Department (DVNI). But it is not until the end of December 2018 that a confidential agreement was reached. The subject of the negotiations has been the limited revenues and the low taxes paid by Apple in France for the last ten years.” A similar agreement was entered by Apple in the UK and Apple in Italy ... Read more

Apple has paid an additional £136m taxes in a settlement with the UK. The settlement is revealed in Apple Europe’s 2017 accounts. “Following an extensive audit by Her Majesty’s Revenue and Customs (HMRC) the Company agreed to pay a corporate income tax adjustment of £136m covering prior years up to September 26, 2015. This payment of additional tax and interest reflects the Company’s increased activity and is recognized in the current financial period which ended on 1 April 2017. As a result of this adjustment the Company’s corporate income tax payments will increase going forward.” Most likely, the HMRC has found that the UK subsidiary had not received a large enough sales- and marketing commission from the Irish Apple sales hub ... Read more

Apple has agreed to paid an additional 347 million dollars to Italy in a settlement with the tax authorities. A spokesperson for the Italian tax office says that Apple is paying the sum to end the investigation, and that it is in line with what the agency had asked for — although substantially less than the €880 million Apple has been accused of withholding for sales booked in Italy. A similar agreement has later been entered into by Apple in the UK and Apple in France ... Read more