In the last quarter of 2007, the European Commission notified Spain of its decision to open a formal investigation procedure under article 88(2) of the EC Treaty concerning the tax regime for the amortisation of financial goodwill. Jose Maria Garcia-Valdecasas Alloza, partner of Balaguer – Morera & Asociados and associate lecturer at the University of Barcelona, explores the EC’s “negative tax harmonisation”
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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
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The deal establishes Ryan’s property tax presence in Scotland and expands its ability to serve clients with complex commercial property portfolios across the UK, the firm said