Income tax treaties can provide significant protections for European investors and businesses in the US. As Congress seeks to close tax loopholes, to generate additional revenue, users of US tax treaties may face even tighter anti-treaty-shopping rules, warn Alfred Groff, Kristen Garry and Nathan Tasso, of Shearman & Sterling.
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The ruling underscores that tax authorities must provide ‘detailed, well-supported, and logically sound justifications’ when determining reference prices in tax assessments, one expert told ITR
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