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Avocado Weekly: Indian Court Orders $132 Million Refund to Vodafone for “Time-Barred” Assessment

Tax authorities took two years to file assessment order

  • India’s High Court of Bombay ordered income tax officials to refund about $132 million (11 billion rupees) to mobile network operator Vodafone Idea Ltd. (Vi Ltd) in funds that had been withheld in a transfer pricing dispute relating to assessment year 2016-2017, according to reports. The court, located in Mumbai, found that the assessment order in the case was “time-barred,” because tax officials waited more than two years to file it after the dispute resolution panel issued its finding in 2021. The court called for a probe into tax officials’ alleged “laxity” and “apathy” in the case. (Bar and Bench) Although the court ordered the tax office to promptly refund the withheld amount to Vodafone Idea, with interest, the office could open a new assessment procedure that complies with the law, a report said. (Live Law)
  • Vietnamese tax officials reportedly froze $4.2 million (102.5 billion dong) in bank assets of Hanoi-based Bamboo Airways because the career allegedly failed to pay taxes within 90 days of the due date. (CH-Aviation)
  •  The UK Supreme Court ruled that Danish tax authorities can go ahead with their 1.4 billion pound ($1.77 billion) cum-ex dividend fraud civil lawsuit in English courts targeting hedge fund founder Sanjay Shah and other traders. (Financial Times
  • Law firm Allen & Overy, headed for a merger with Shearman & Sterling, was hit by a cyberattack this week, according to a report from London. (The Lawyer)
South Korea Plans Updated Pillar Two Guidance in December
  • South Korea plans to publish revised tax decrees in December, including updated OECD Pillar Two guidance, in a move to pave the way for the country to begin implementing the 15% global minimum corporate tax rules starting Jan. 1, 2024.  Around 200 South Korean companies, including tech giant Samsung Electronics Co., are expected to be affected by the rules, which are aimed at ensuring the world’s biggest companies pay their fair share of taxes in countries where they earn revenues. (Yonhap News)
  • Deloitte’s German branch said advising clients on OECD Pillar Two and on transactions powered 14.1% revenue growth for its tax and legal arm for 2022-2023, to about 343 million euros ($368.3 million). The branch’s overall revenues climbed to 2.33 billion euros, its first time past the $2 billion threshold, according to a German-language report. (Juve.de) (Deloitte.com)
  • A Mississippi jury found three tax return preparers guilty of tax fraud. (Justice.gov)
  • The Organization for Economic Cooperation and Development’s Global Forum on Transparency and Exchange of Information for Tax Purposes released eight new peer review reports of members. (OECD.org)
Pinsent Masons Recruits VAT Specialist
  • Pinsent Masons hired valued-added-tax specialist Bryn Reynolds, a chartered accountant and tax adviser, as partner into its London office. He arrives from Simmons & Simmons, where he was principal, and was earlier at EY and KPMG. (PinsentMasons.com)
  • Law firm Quarles & Brady is opening an office in St. Louis, Missouri, with 10 lawyers, including three who advise on tax. (Quarles.com)
  • UK litigation firm Stewarts hired longtime tax litigator Giles Salmond, who was Eversheds-Sutherland’s UK head of indirect taxes and tax dispute resolution, as partner on its tax litigation and resolution team. (StewartsLaw.com)
  • Armstrong Teasdale hired tax and estate-planning lawyer Keith Grissom as partner in its headquarters at Saint Louis, Missouri. He arrives from Greensfelder Hemker & Gale. (Armstrong Teasdale)

Startup Launches AI-Powered Tax Tool
  • Artificial intelligence startup Black Ore Technologies Inc., which recently raised $60 million in financing, launched its first product, Tax Autopilot, a tax preparation tool aimed at accountants. (PYMNTS)
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