In reaction to the European Court of Justice’s (ECJ) October 20 2011 judgment, on March 1 2013 Germany passed a law according to which EU and EEA corporations are allowed to apply for a refund of the German dividend withholding tax on portfolio dividends under certain conditions.
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Experts reportedly discussed extending the safe harbour to 2027 to give countries more time to legislate; in other news, Baker McKenzie and Greenberg Traurig made senior tax hires
Hany Elnaggar examines how Gulf Cooperation Council countries are internalising transfer pricing norms within evolving fiscal systems shaped by both Islamic and international influences
Where a TP study of comparables produces an arm’s-length range, and the taxpayer’s filed position is outside that range, HMRC will adjust to the median by default