Understanding Double Tax Treaties: A Comprehensive Guide
*For clarity, the term Double Tax Treaty (DTT) used in this article has the same meaning as Double Tax Agreement […]
Understanding Double Tax Treaties: A Comprehensive Guide Read Post »
*For clarity, the term Double Tax Treaty (DTT) used in this article has the same meaning as Double Tax Agreement […]
Understanding Double Tax Treaties: A Comprehensive Guide Read Post »
Mutual Agreement Procedures (MAP) are key mechanisms that ensure fair tax treatment in international transactions. They help resolve conflicts between tax authorities, avoiding double taxation and promoting business growth.
Mutual Agreement Procedures (MAP): Key Guidelines Read Post »
This case revolves around the European Commission’s appeal against the General Court’s decision to annul the Commission’s ruling that Ireland granted Apple unlawful state aid through favourable tax rulings.
Apple vs. European Commission Read Post »
The dispute focused on the income tax treatment of intellectual property (IP) transactions between 3M’s U.S. subsidiaries and its Brazilian subsidiary, 3M do Brasil Ltda (3M Brazil), for the tax year 2006.
The case revolved around whether Nokia Solutions and Networks Oy had a Permanent Establishment (PE) in India, and whether profits could be attributed to that PE under the India-Finland Double Taxation Avoidance Agreement (DTAA).
Nokia vs. India: Permanent Establishment and Profit Attribution Dispute Read Post »
In Lexel AB v Skatteverket (Case C‑484/19), the Court of Justice of the European Union (CJEU) ruled that Swedish tax legislation, which denied Lexel AB the right to deduct interest payments made to a group company located in another EU Member State (France), infringed upon the freedom of establishment protected under Article 49 TFEU.
The Cadbury Schweppes case is a seminal ruling in the context of the European Union’s freedom of establishment and the limitations on Member States’ tax authorities to impose tax measures on Controlled Foreign Companies (CFCs).
Cadbury Schweppes vs UK: EU Ruling on Freedom of Establishment and Tax Avoidance Read Post »
The case revolves around cross-appeals by Motorola, Ericsson, and Nokia against the Income Tax Department of India, challenging the taxability of revenues generated from the supply of equipment and software to Indian telecom operators.
Motorola Inc. vs. India (DCIT) Read Post »