On September 23, the Canadian Federal Court of Appeal released the highly anticipated decision in Daishowa-Marubeni. Doug Richardson and Julie D’Avignon of Stikeman Elliott explain why the decision is of particular interest to every mining, energy and forestry company that has bought or sold assets in circumstances where reclamation or reforestation obligations were assumed by the purchaser as part of the sale.
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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
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems
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