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 Fenwick & WestThe Ninth Circuit reversed, and then withdrew its reversal of, the Tax Court's unanimous 'reviewed by the court' decision in Altera Corp. v. Commissioner, 145 T.C. 91 (2015), and held in a 2-1 decision that Treas. Reg. § 1.482-7(d)(2), requiring related entities to share the cost of employee stock compensation (the 2003 Regulation) was a valid regulation. -
Sponsored by Dhruva AdvisorsRecently, the Income Tax Appellate Tribunal gave an important judgement regarding the creation of and attribution of profits to an agency permanent establishment (Agency PE) – Daikin Industries v ACIT ('ITA No 1623 of 2015 [New Delhi Income Tax Appellate Tribunal, May 28 2018]').
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Sponsored by Mattos FilhoAfter launching the Zelotes operation, the discussion on the restructuring of the Administrative Tax Appeals Council (CARF) was intensified. In relation to this, there are at least six bills pending before the Brazilian Congress, write João Marcos Colussi and Gabriel Mendes Gonçalves Issa of Mattos Filho.
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