The Supreme Tax Court in Germany has clarified that not only did the country’s old thin capitalisation rules not comply with the freedom of establishment provision of the European Community (EC) treaty, but they also infringed the non-discrimination clause of treaties relating to companies resident in non-EC countries.
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Authors from Khaitan & Co evaluate the recent CBDT notification, whereby legacy investments made by investors continue to be exempt from the applicability of GAAR
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