Jack Taylor, University of Minho, discusses the long-term implications of the U.S. Court of Appeals for the Sixth Circuit’s March 2 reaffirmation of the previous December 2021 decision in Whirlpool v. Commissioner of Internal Revenue, which held that Whirpool must pay taxes on USD 45 million in income.
Leopoldo Parada, University of Leeds School of Law, analyzes the three grounds of appeal in the Fiat Chrysler Finance Europe v Commission case and warns that if the European Court of Justice agrees to follow the Advocate General’s opinion, there may be important ramifications that go beyond this transfer pricing case.
Geoffroy Galéa, Alain Thilmany, and Cassandre Guéry, Fieldfisher, discuss the European Commission’s 22 December 2021 publication of the ATAD III directive, which will increase the tax authorities’ attention to the international concept of substance; more than ever, it is crucial for multinational groups to . . .
New York City Economist Dr. J. Harold McClure analyzes the Supreme Court of Canada’s November 26 decision upholding a taxpayer-favorable ruling in The Queen v. Alta Energy Luxembourg S.A.R.L., in which the legal issue revolved around charges of treaty shopping, but the appropriate valuation of . . .
Gela Barshovi a tax adviser and managing partner of TPsolution, Tbilisi, discusses the Republic of Georgia’s July 23 publication of the synthesized text of tax treaties with five countries, as amended by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting . . .
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