The Official Journal of the European Union of September 9 2004 contained the European Commission's invitation to submit comments to its letter to the Italian Government of May 7 2004 where it claimed that a certain Italian tax incentive should be treated as an illegitimate State aid pursuant to articles 87 and following of the EU Treaty
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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