Europe
ITR understands that UK Chancellor Rachel Reeves will announce a consultation on the proposed financial reward scheme, which had left advisers fretting
The long-running dispute centres on Medtronic’s use of the comparable uncontrolled transaction TP method; in other news, Paul Hastings and FTI Consulting both made double tax hires
The US itself was the biggest loser of tax revenue to American multinationals’ profit shifting, the Tax Justice Network reported; in other news, firms made key tax hires
The president described it as ‘one of the most important cases in the history of our country’; in other news, Portugal established a VAT group regime
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Sponsored by MDDPMarek Kończak and Tomasz Janik of MDDP say Poland’s draft amendment to the Corporate Income Tax Act addresses two key CJEU rulings but leaves open questions on scope, timing, and safeguards -
Sponsored by Deloitte LuxembourgEdouard Authamayou of Deloitte Luxembourg examines a tribunal ruling on hidden contributions and profit distributions that highlights the importance of robust evidence supporting the arm’s-length principle in intragroup financing arrangements and interest rate waivers
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Sponsored by MDDPPoland: Clarified beneficial ownership rules and introduction of overseas investment fund exemptionsJustyna Bauta-Szostak and Gniewomir Parzyjagła of MDDP say the new guidance on withholding tax is a step forward for businesses operating across borders and overseas funds investing in Poland
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European Jurisdictions