The European Commission has formally requested that Germany amends its anti-abuse provisions on withholding tax relief. While not criticising the aim of the anti-abuse measure, the Commission is concerned about the disproportionality of one provision under which companies have to prove the existence of genuine economic activity of their foreign subsidiaries to obtain the relief.
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Valid pillar two objectives are still intact after the side-by-side agreement, but whether the framework is now settled is ‘a $64,000 question’, Morrison Foerster’s tax chair told ITR
The firms made senior hires in Los Angeles and Cleveland respectively; in other news, South Korea reported an 11% rise in tax income, fuelled by a corporation tax boom
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