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,...
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TODAY'S ISSUES
GTC Global
Nov 21, 20232 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 15, 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
Oct 31, 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 24, 20231 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 17, 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 10, 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
Sep 26, 20232 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...
GTC Global
Sep 19, 20231 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...
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