The European Court of Justice’s (ECJ) second judgment in the Franked Investment Income Group Litigation (FII GLO) clarifies when EU taxpayers can rely on free movement of capital for outward investments into non-EU jurisdictions. It also highlights the need for an answer regarding inward investment from non-EU taxpayers.
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India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
ITR sat down for a pre-event interview with Tim Zech, WTS Germany, and Jeff Soar, WTS UK, keynote speaker at next week’s ITR AI in Tax Forum 2026 in London
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