Europe
Partners are divided on Italy vs PDM D’s analytical depth, evidentiary standards, and what the judgment signals for future intra-group financing cases
While all options presented ‘drawbacks’, European Commission tax leader Wopke Hoekstra said the controversial US carve-out deal has ‘many benefits’
Despite estimates that the US/OECD agreement will cost countries billions, the Fair Tax Foundation’s Paul Monaghan believes the deal is a ‘necessary evil’
The firm’s eye-catching UK launch is a major statement of intent, but it will face stern opposition in its quest to be the top global tax player
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Sponsored by CuatrecasasA recent ruling curbs formalistic proof requirements in EU cross-border pension fund taxation while strengthening the substance over form and ‘equality of arms’ concepts, say João Rodrigues, Liliana Piedade, and Francisco Ludovino Reis of Cuatrecasas -
Sponsored by VdATiago Marreiros Moreira and Francisca de Landerset of VdA explain the challenges of attributing profits to a management permanent establishment in Portugal, highlighting OECD guidance, board member activities, and documentation requirements for compliance
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Sponsored by Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici examine key issues in Italy’s transposition of DAC8 and the challenges posed by technological transformation in the digital economy
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European Jurisdictions