Welcome to the second issue of Norton Rose Fulbright’s Tax controversy insights.
Tax controversy lawyers with Norton Rose Fulbright around the globe have prepared an inaugural survey of certain tax controversy procedures and issues for Australia, Canada, Germany, Italy, South Africa, the United Kingdom, and the United States.
While each tax controversy will involve unique circumstances, this survey serves as a reference tool for tax executives at multinational companies. It will be an evolving tool, and we plan to add additional countries in future surveys.
This additional includes procedures and issues for:
- Collection of information
- Dispute resolution - administrative
- Transfer pricing
- Civil and criminal penalties
- Judicial challenges
- Privilege protection for information
- Statutes of limitations
- Reconciliation of laws/application of doctrines
The Collision Regulations and Autonomous Shipping
In the May 2019 edition of Legalseas, we reflected on the implication of the Court of Appeal decision in the case of Evergreen Marine v Nautical Challenge (Evergreen) when considering the interaction (and interpretation) of the Collision Regulations (COLREGs) (specifically the crossing rule (Rule 15) and narrow channel rule (Rule 9)) in circumstances when they appeared to conflict.