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There are 33,170 results that match your search.33,170 results
  • Court clarifies criteria for fixed place PE
    An Indian court has outlined the three criteria that taxpayers must satisfy to constitute a fixed-place permanent establishment.
    January 01 2010
  • ECJ answered wrong question, says German court
    The Federal Fiscal Court (Bundesfinanzhof – BFH) has decided that Germany's switchover clause for taxing income from foreign partnerships is incompatible with EU law, even though the European Court of Justice (ECJ) reached the opposite conclusion in the same case, Columbus Container Services v Finanzamt Bielefeld-Innenstadt (C-298/05).
    January 01 2010
  • Transfer of Indian shares not liable to tax, say authority
    An Indian tax panel has ruled that the transfer of an Indian company's shares between non-residents is not liable to tax.
    January 01 2010
  • Wells Fargo decision sheds light on economic substance doctrine
    The decision that the Court of Federal Claims reached in the case of Wells Fargo & Company and Subsidiaries v United States on January 8 is still reverberating in the US tax community.
    January 01 2010
  • Tribunal outlines importance of transactional differences
    An Indian court has underscored the importance of taxpayers making accurate transaction adjustments on account of different conditions in varying locations.
    January 01 2010
  • Indian tribunal confirms royalty decision
    An Indian tribunal has reiterated that payment for supplying shrink-wrapped software does not result in transfer of copyright or the right to use copyright, so cannot be considered as royalty.
    January 01 2010
  • Gaming arcades get unlucky break in European Court
    In a decision that could affect sectors of the gambling industry across the EU, the European Court of Justice (ECJ) has upheld Germany's imposition of VAT on gaming machine operations.
    January 01 2010
  • Authority favours taxpayer over Indian R&D expenses
    The Authority for Advance Rulings has held that the reimbursement of research R&D expenses under a cost contribution agreement is not liable to tax in India.
    January 01 2010
  • German supreme court reverses squeeze-out compensation position
    The Supreme Court of Germany (BGH) has partially reversed its position on the method and reference period used for determining cash compensation when a majority shareholder wants to squeeze-out and delist a company from the market.
    January 01 2010
  • Panellists to share dispute resolution experiences
    The dispute resolution panel at International Tax Review's Global Transfer Pricing Forum will focus on planning transfer pricing policies to avoid disputes, achieving settlements and using advanced pricing agreements (APAs).
    January 01 2010
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