The Treasury recently finalized an amendment to its regulations on qualified cost-sharing arrangements (QCSAs) requiring that the deemed cost of stock options and other stock-based compensation be treated as a development cost to be shared with the participants of a QCSA along with the cash-based compensation of the employees involved in the development of intangibles subject to the arrangement
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The Court of Appeal ruling clarifies that treaty benefits are not abusive where transactions are commercially driven, providing greater certainty on “main purpose” anti-avoidance tests
Despite the Netherlands featuring an unusual concentration of World Tax-ranked technology-led providers, sources believe there’s a long way to go to challenge the established players
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