In a recently published decision, the German Federal Fiscal Court (BFH) ruled that the German thin capitalisation regulations (interest barrier rule) may violate the principles of fair taxation as laid down in the German Constitution. Affected taxpayers should take all measures to keep their assessments open and to stay the execution of their tax assessment notice.
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While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems