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...
top of page
TODAY'S ISSUES
GTC Global
Sep 5, 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...
GTC Global
Aug 29, 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...
GTC Global
Aug 22, 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 15, 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 8, 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 2, 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%);...
GTC Global
Jul 25, 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...
GTC Global
Jul 14, 20231 min read
Decision of the Tax Court (US) in Medtronic, Inc and Consolidated Subsidiaries v. Commissioner
The Tax Court decided to disregard both the IRS’s and the assessee’s transfer pricing analysis by adopting an unspecified method. As for...
GTC Global
Jul 5, 20232 min read
Decision of the French Conseil d’Etat (French Supreme Administrative Court) in Sacla SA v. Ministre
Sacla SA, a French Company, sold a set of brands for EUR 90,000 to its wholly-owned subsidiary in Luxembourg. The French tax authorities...
bottom of page