6/28/2023 1:38:01 PM Spanish Supreme Court follows CJEU's case law: dividend distributions within the EU shall be tax exempt unless the tax authorities prove abuse By David López Carlos Arrieta Martínez In a recent ruling issued on 8 June 2023, the Spanish Supreme Court followed the Court of Justice of the European Union’s decisions in...
6/26/2023 1:08:53 PM New Brazilian Transfer Pricing Framework: moving towards the OECD standard By Dante Zanotti Arthur Almeida Law No. 14,596 aligns the Brazilian transfer pricing rules with the standards embodied by the OECD Transfer Pricing Guidelines and...
6/23/2023 9:31:48 AM Transfer pricing, permanent establishment and diverted profits tax reform By Tanja Velling The changes proposed by the UK government in its consultation on the reform of the transfer pricing, permanent establishment and diverted...
6/19/2023 9:47:19 AM German tax administration gets the attention of US Congress for register cases By Sebastian Heinrichs The German register cases have been the subject of discussions in the public and also in this blog for almost three years, from the start...
6/8/2023 3:00:01 PM Hargreaves Property Holdings v HMRC: Beneficial entitlement and “yearly” interest By Kasim Mehmood The Upper Tribunal’s decision is a helpful ‘back-to-basics’ on the nature and purpose of the provisions on withholding tax on interest...
6/1/2023 3:59:52 PM And what about Brexit? By Zoe Andrews Tanja Velling During a debate on the Spring Finance Bill, Gareth Davies, Exchequer Secretary to the Treasury, emphasised the UK government’s intention...