Europe
The long-running dispute centres on Medtronic’s use of the comparable uncontrolled transaction TP method; in other news, Paul Hastings and FTI Consulting both made double tax hires
The US itself was the biggest loser of tax revenue to American multinationals’ profit shifting, the Tax Justice Network reported; in other news, firms made key tax hires
The president described it as ‘one of the most important cases in the history of our country’; in other news, Portugal established a VAT group regime
Clients are facing increased TP audit scrutiny in Hungary. DLA Piper Hungary is therefore using AI and advanced analytics to augment its advice, the firm’s head of TP says
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Sponsored by Deloitte LuxembourgDinko Dinev and Iva Gyurova of Deloitte Luxembourg analyse a landmark ruling on how economic substance plays a key role in determining whether interest-free loans from indirect shareholders constitute debt or equity for Luxembourg tax purposes -
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
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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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European Jurisdictions