Tax Disputes
Growing GAAR scrutiny is driving taxpayers to look beyond legal form and demonstrate the commercial rationale underpinning tax-efficient structures
Among the arrivals is Andrew Howell, who leaves scandal-hit PwC Australia after representing PepsiCo in a high-profile TP dispute
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2026 Europe Tax Awards
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
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Sponsored by KPMG SwedenMaria Andersson and Karolina Viberg of KPMG Sweden analyse a judgment delivered by the Administrative Court of Stockholm which sheds some light on the STA’s view on economic ownership of intangibles and DEMPE functions. -
Sponsored by Morais Leitão, Galvão Teles, Soares da Silva & AssociadosPaulo Núncio and António Queiroz Martins from Morais Leitão analyse the landmark decision by a Portuguese arbitral court which ruled that the PT bank levy, applicable to Portuguese branches of EU banks, breaches EU law.
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Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US take a closer look at the US Tax Court’s opinion in the Adams Challenge case and consider its implications for taxpayers on the OCS.
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