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TODAY'S ISSUES
Mexican GAAR: Economic Substance and Business Purpose Scrutiny
2023 The Mexican Tax Administration Service (SAT) has applied the General Anti-Avoidance Rule (GAAR) in a recent case involving a...
GTC Global
5 days ago1 min read
Delhi High Court Rules on Service Fees and Profit Attribution to PE in Hyatt Case December 2023
October 16, 2023 The Delhi High Court addressed a dispute involving Hyatt International Southwest Asia Ltd. and the Indian tax...
GTC Global
May 71 min read
U.S. Tax Court Applies Unspecified Method in Medtronic Transfer Pricing Dispute
August 2022 The U.S. Tax Court ruled on a transfer pricing dispute between Medtronic and the IRS regarding the appropriate method to...
GTC Global
Apr 281 min read
Czech Supreme Court Confirms Cost Plus Method in Intra-Group Services Case
July 2024 The Czech Supreme Administrative Court ruled on a transfer pricing dispute between BEAS SUN s.r.o. and the tax authorities...
GTC Global
Apr 71 min read
Dutch Court Upholds Transfer Pricing Adjustment in Agri B.V. Restructuring Case
July 2024 The Dutch Court of Appeal ruled on a transfer pricing dispute between “Agri B.V.” and the tax authorities concerning the...
GTC Global
Mar 311 min read
Luxembourg Tribunal Rejects PE Claim in U.S. by “A IGF s.a.r.l.”
July 2024 The Luxembourg Administrative Tribunal ruled on an intra-group financing dispute between “A IGF s.a.r.l.” and the tax...
GTC Global
Mar 171 min read
Italian Supreme Court Rules on Costa Crociere Transfer Pricing Dispute
July 16, 2024 The Italian Supreme Court ruled on a transfer pricing dispute concerning Costa Crociere and its Brazilian subsidiary, Costa...
GTC Global
Mar 71 min read
France’s Highest Court Upholds Tax Adjustments in Howmet SAS Case
Dated 23 July 2024 The Conseil d’État dismissed Howmet SAS’s appeal against tax adjustments imposed by French authorities following...
GTC Global
Feb 271 min read
ECJ Upholds Validity of EU Tax Reporting Directive Amid Legal Challenges
Dated 29 July 2024 The Belgian Constitutional Court sought guidance from the European Court of Justice (ECJ) on the validity of reporting...
GTC Global
Jan 201 min read
Transfer Pricing and Comparability Adjustments: Bulgarian Administrative Court Rules in Favor of Yazaki Bulgaria Ltd
Dated January 5, 2023 In Yazaki Bulgaria Ltd v Bulgarian Tax Authorities, the Administrative Court reviewed the tax authority’s...
GTC Global
Jan 151 min read
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