Europe
The judgment, which saw Denmark's Supreme Court rely on OECD TP guidance, sets aside more than 15 years of consistent administrative practice, experts have told ITR
Belgium’s new coalition government has gone ahead with a new exit tax regime that could land it in the courts.
Jaap Zwaan’s arrival continues a recent streak of A&M Tax investing in the region; in other news, the US and Japan struck a deal that significantly lowered tariff rates
France v Axa provides a practical illustration of how the burden of proof is applied in TP matters under French law, ITR also heard
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Sponsored by MDDPMarek Kończak and Tomasz Janik of MDDP say Poland’s draft amendment to the Corporate Income Tax Act addresses two key CJEU rulings but leaves open questions on scope, timing, and safeguards -
Sponsored by Deloitte LuxembourgEdouard Authamayou of Deloitte Luxembourg examines a tribunal ruling on hidden contributions and profit distributions that highlights the importance of robust evidence supporting the arm’s-length principle in intragroup financing arrangements and interest rate waivers
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Sponsored by MDDPPoland: Clarified beneficial ownership rules and introduction of overseas investment fund exemptionsJustyna Bauta-Szostak and Gniewomir Parzyjagła of MDDP say the new guidance on withholding tax is a step forward for businesses operating across borders and overseas funds investing in Poland
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European Jurisdictions