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TODAY'S ISSUES
India - Decision of the High Court of Delhi (India) in Principal Commissioner of Income-tax v. Hellmann Worldwide Logistics India, [2023] 155 taxmann.com 44
Dated 04 October, 2023 In an appeal by the tax department against a decision by the Income Tax Appellate Tribunal (ITAT) regarding the...
GTC Global
Feb 15, 20242 min read
United States - Decision of the U.S. Court of Appeals in United States vs GSS HOLDINGS (LIBERTY) INC., Case No. 21-2353
Dated 21 September 2023 The U.S. Court of Appeals for the Federal Circuit overturned a lower court decision in a case involving GSS...
GTC Global
Jan 30, 20242 min read
Belgium - Decision of the EU General Court in European Commission vs. Belgium, Case T 131/16 RENV
Dated 16 September, 2023 Between 2004 and 2014, Belgium allowed certain multinational group members to reduce their taxable basis,...
GTC Global
Jan 25, 20241 min read
BlackRock – Loans and ALP - Decision of the UK Upper Tribunal in Case No [2022] UKUT 00199
dated 19 July 2022 In 2009, BlackRock Group purchased Barclays Global Investors for $13.5 billion, partly paid in shares ($6.9bn) and...
GTC Global
Nov 21, 20232 min read
Kellogg India – Resale Price Method - Decision of the Income Tax Appellate Tribunal in Mumbai, India
dated 12 February 2022 The Income Tax Appellate Tribunal (ITAT) in Mumbai, India, supported Kellogg India in a case regarding the...
GTC Global
Nov 15, 20232 min read
Profit Shifting - Decision of the French Conseil d’État in Case No 464928 - France vs ST Dupont
Dated 05 July 2023 ST Dupont, a French luxury goods maker, primarily owned by Dutch company D&D International and Hong Kong-based Broad...
GTC Global
Oct 31, 20232 min read
U.K. – “Special Capital Schemes” Corporate Partners - Odey Asset Management v HMRC [2021] UKFTT 36 /
Odey adopted a remuneration policy under which a proportion of Odey's profits which could otherwise have been allocated to and received...
GTC Global
Oct 24, 20231 min read
Belgium - DEMPE - BE: Court of Appeal (Ghent), 8 June 2021, No. 2016/AR/455The Belgium Court of Ap
The Belgium Court of Appeal in Ghent ruled in favor of the taxpayer in a complicated transfer pricing case involving intangibles. The...
GTC Global
Oct 17, 20231 min read
Italy – Italian Transfer Pricing Provisions (TNMM Application) - Decision No. 15668/2022
Promgas s.p.a., a company equally owned by Italian Eni s.p.a. and Russian Gazprom Export, engages in buying and selling Russian-origin...
GTC Global
Oct 10, 20231 min read
Netherlands/ India – MFN Clauses - Koninklijke Philips N.V. v. DCIT.
A Dutch company, having received interest on a tax refund from the Indian government claimed that such interest was not taxable in India....
GTC Global
Oct 10, 20231 min read
German Federal Tax Court PE Definition - BFH of 23 March 2022
On 23 March 2022, Germany's federal tax court (BFH) made a ruling published on 11 August 2022 regarding German third-party property...
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Sep 26, 20232 min read
EU - Fiat – State-Aid - ECJ Joint Cases C-885/19 P and C-898/19 P)
The Court of Justice of the European Union's has given its final Landmark Decision on the Fiat Finance & Trade Ltd State Aid...
GTC Global
Sep 19, 20231 min read
Decision of the Income Tax Appellate Tribunal in India vs Google India Private Limited, Oct. 2022
Income Tax Appellate Tribunal, 1513/Bang/2013, 1514/Bang/2013, 1515/Bang/2013, 1516/Bang/2013 Google Ireland licences part Google AdWords...
GTC Global
Sep 12, 20231 min read
Decision of the Supreme Court of Canada in: Canada v. Alta Energy Luxembourg S.A.R.L., 2021 SCC
In 2011 Alta Energy Partners Canada Ltd. (Alta Canada) was a Canadian-incorporated company and fully owned subsidiary of Alta Energy...
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Sep 5, 20231 min read
Decision of the Supreme Court of The Netherlands in Case No. 21/00299 dated 03 March 2023
The case deals with interest deduction limitation under Section 10 a of the Corporate Income Tax Act of 1969. The issue arose in respect...
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Aug 29, 20231 min read
Ruling of the Stockholm Administrative Court (Sweden) in Re: Pandox AB dated 28 February 2022
Pandox AB, headquartered in Sweden, owns around 157 hotel properties in 15 Northern European countries. As per its transfer pricing...
GTC Global
Aug 22, 20231 min read
Decision of the Tel-Aviv District Court (Israel) in Tax Appeal 53528-01-16 dated 08 May 20228
Medingo Ltd., incorporated in Israel, (developer of a proprietary insulin pump) and its foreign holding company, Roche pharmaceutical...
GTC Global
Aug 15, 20231 min read
Decision of the Regional Administrative Court of Gorzow Wielkopolski (Poland) in I SA/Go 234/22
H. LVAS Sp. z oo, incorporated in Poland, deducted expenses related to intra-group services in its taxable income. The services had been...
GTC Global
Aug 8, 20231 min read
Decision of the Federal Tax Court (Germany) in I R 62/17
A German company acquired shares in a company, which was financed as follows: unsecured subordinated shareholder loan (interest rate 8%);...
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Aug 2, 20231 min read
Decision of the Tax Court (United States) in 3M Co. v Commissioner
In 2006 3M Co entered into a licensing arrangement where certain intangibles were made available to its Brazilian subsidiary. Brazilian...
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Jul 25, 20231 min read
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