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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 DS AvocatsSandra Louiset of DS Avocats reports that the Council of State has taken a novel position regarding a state’s right to tax. -
Sponsored by DLA Piper AustraliaAdam Smith of DLA Piper Australia reports on the New South Wales Supreme Court’s ruling that three hydroelectric power stations constituted property outside the traditional categories used in determining the character of an interest.
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Sponsored by MDDPMagdalena Dymkowska of MDDP provides a guide to the vagaries of the Polish transfer pricing regulations and explains why the applicability of the arm’s-length rule may leave multinational companies somewhat surprised.
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