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The Court of Appeal ruling clarifies that treaty benefits are not abusive where transactions are commercially driven, providing greater certainty on “main purpose” anti-avoidance tests
Despite the Netherlands featuring an unusual concentration of World Tax-ranked technology-led providers, sources believe there’s a long way to go to challenge the established players
Ethics seems to be playing a subservient role to an entitlement culture borne out of a pervasive ‘revenue at all costs’ mentality at the big four
Historical World Tax data suggests the ‘largest law firm merger in history’ may not pose a serious threat to the world's leading tax practices
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Sponsored by Skeppsbron SkattMikael Jacobsen and Henri Ahtiainen of Skeppsbron Skatt explore how several recent Swedish cases have shed light on the complex distinction between legal and economic ownership of intellectual property in transfer pricing matters
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Sponsored by YulchonWith South Korea expected to intensify its focus on multinationals’ intercompany transactions during tax audits, Yulchon tax partners analyse several transfer pricing-related rulings that could help shape strategy
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Sponsored by Tax PartnerMonika Bieri and Caterina Colling Russo of Tax Partner discuss a Swiss court ruling concerning the use of multi-year margin averaging in transfer pricing adjustments and suggest several steps that could help ensure compliance
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