As the UK High Court is about to give details of its referral of a thin-capitalization group litigation order to the European Court of Justice (ECJ), Philip Martin, formerly deputy head of tax at retailer Marks & Spencer, has abruptly left Dorsey & Whitney, the US law firm handling the order for claimants including Pepsi, Volvo and a subsidiary of Caterpillar
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Geopolitical rivalry is reshaping global tax cooperation, as the OECD’s minimum tax framework fragments and the EU grapples with the ensuing legal fallout
Chile’s revamped GAAR marks a shift toward structural scrutiny, pushing MNEs to strengthen tax governance, economic substance and compliance strategies
While the IBS incorporates taxable events previously covered by state and municipal taxes, its governance and operational logic represent a significant departure from the legacy model