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The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, and rejects protection for indirect transfers and tightening 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
Partners want to join Ryan because it’s a disruptor firm, truly global and less bureaucratic, Tom Shave told ITR
The Netherlands-based bank was described as an ‘exemplar of total transparency’; in other news, Kirkland & Ellis made a senior tax hire in Dallas
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Sponsored by Garrigues SpainMaría Cenzual and Marta Gràcia of Garrigues report on the Supreme Court overturning the Spanish tax authorities’ stance that borrowing costs in certain circumstances should be treated as gratuities for corporate income tax purposes. -
Sponsored by Deloitte NorwayDaniel Herde and Lene Bergersen of Deloitte Norway explain a statement from the Ministry of Finance on the relationship between Article 8 (shipping income) and Article 12 (royalties) in double tax treaties.
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Sponsored by DLA Piper AustraliaEddie Ahn of DLA Piper Australia provides an update on the Minerva Financial Group v Federal Commissioner of Taxation case, which considered the application of Australia’s general anti-avoidance rules to a business restructure.
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