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Introduction On 28 November 2024, the European Commission adopted Decision (EU) 2025/2405, formally closing its long-running State aid investigation into the Luxembourg tax ruling granted to Amazon in 2003. This decision is significant not because it reopens the substantive transfer pricing debate, but because it confirms, following the Court of Justice’s Amazon judgment, that the assessment of State aid must be strictly anchored in the national corporate income tax framework

Introduction The Czech Supreme Administrative Court has upheld additional corporate income tax assessments issued to Aufeer Design s.r.o. for the tax years 2015 and 2016. The dispute centred on substantial advertising fees paid to HERA s.r.o. for the placement of Aufeer banners at various events. The tax authorities classified the arrangement as akin to a related-party relationship, concluding that the remuneration for advertising services was excessive and did not reflect ma

Introduction In May 2025, the European Commission issued the EU Start-up and Scale-up Strategy, a far-reaching framework aimed at making Europe the world’s most competitive jurisdiction for launching and scaling innovative companies. The Strategy highlights that despite Europe’s strong research base, startups continue to face administrative burdens, slow incorporation procedures, and fragmented rules. To address these, the Commission proposes harmonized company-law tools, dig

The 2025 fiscal reform in Mexico deserves close attention, not because it is another routine amendment to the Federal Tax Code, but because it redefines the way the tax authority communicates with taxpayers, supervises their activity and evaluates their conduct. The changes are substantive. They modify expectations, reshape the audit process and require a more proactive approach to compliance. At the center of this reform is Article 49 BIS, a new procedural provision that est

Introduction In The Hexadite Case, the Tel Aviv Jaffa District Court Tax Authority in Cybersecurity case issued a significant judgment concerning the valuation of assets transferred following Microsoft’s USD 75 million acquisition of Hexadite Ltd., an Israeli cybersecurity company. Shortly after the share purchase, Hexadite transferred its intellectual property, personnel, and business functions to Microsoft group entities. The Tax Authority challenged the reported valuation

Introduction In the present article, we explore why expats need international tax advisers. It is common to mistakenly assume that tax obligations cross-borders correspond only to High Net Worth Individuals, however as it will be disclosed in the present article any remunerated activity cross-border may be subject to tax. Therefore, we understand expats not only as defined for High Net Worth Individual although also cross border workers, directors and professionals in the ent

Introduction Expanding into the European Union (EU) Startups often find that each country has its own rules, and EU-wide regulations add another layer of complexity.  In fact, 70% of startups that expand internationally face at least one unexpected tax hit within their first three years. These surprises aren’t due to wrongdoing, but rather the speed of expansion and the complexity of multi-jurisdictional operations. A recent EU survey also confirms that tax and regulatory iss

Introduction Tobacco BV received multiple tax assessments covering the years 2008-2016 with substantial corrections to declared income, along with penalties for several years. The dispute centred on whether fees paid to group companies factoring fees, guarantee fees, service charges, royalties, and other intra-group costs were effectively aligned with the arm’s-length principle under Section 8b of the Dutch Corporate Income Tax Act. The Dutch Court Pivotal Financial Transfer

Introduction: Companies expanding into Europe must take into account different factors when deciding to establish themselves within a member state. The European Framework rewards only those which follow and comply with its regulations and directives and in the present article we will provide an overview of general obligations to be regarded when considering moving into the European Union. In brief: Establishing Entities Without Real Substance. Overlooking Anti-Abuse and Subs

Overview The Tribunal examined whether payments by Vodafone Idea Ltd.  (“the assessee”) to its Ireland-based associated enterpris e  for management and technical services were at arm’s length. The Transfer Pricing Officer (TPO) disallowed the entire expense, alleging that the assessee failed to prove any “tangible benefit.” The ITAT set aside this adjustment, holding that the TPO had exceeded his jurisdiction by questioning the business prudence of the transaction. The ruling

Many startups in Europe misunderstand the treatment of input VAT (tax paid on business purchases) and output VAT (tax charged on sales). In the early stages, companies often fail to recover input VAT because they lack compliant invoices, have not yet registered for VAT, or cannot demonstrate a direct link between the purchase and their business activity. Conversely, output VAT is sometimes reported late or inconsistently, especially during pre-revenue periods. These mistakes

Introduction In the case of National Tax Tribunal (Denmark), Case No. SKM2025.590.LSR, decided in October 2025, the Danish tax authority challenged the tax deductibility of interest on a promissory note issued in connection with the acquisition of a 50 % shareholding of a foreign company held by Holding A/S (and related purchaser entities).  The controversy involves the restructuring of share-transfer and financing   steps: The purchaser companies (three related entities) ac

Introduction: On October 2025, the OECD Released 2025 MAP Consolidated Report for 2025, providing a comprehensive assessment of how 141 jurisdictions manage cross-border tax disputes and prevent double taxation. The report, forming part of the OECD’s continuing implementation of the Base Erosion and Profit Shifting (BEPS) Action 14 Minimum Standard, confirms ongoing improvements in dispute resolution efficiency, with Switzerland and New Zealand ranking among the fastest and

Introduction The Brazilian Ministry of Finance introduced before the G20 a proposal to establish a global minimum tax on ultra-high-net-worth individuals (UHNWIs). The initiative, supported by reports from the Addis Tax Initiative (ATI), the Tax Justice Network, and analyses from professional advisors, aims to ensure that extreme concentrations of wealth contribute fairly to global public finances. Summary of the Regulation The proposal seeks to impose a minimum tax burden o

Introduction The Full Federal Court of Australia, in Oracle Corporation Australia Pty Ltd v Commissioner of Taxation [2025] FCAFC 145 , overturned the Federal Court’s 2024 decision and granted Oracle a stay of domestic proceedings pending the completion of a Mutual Agreement Procedure (MAP) under the Australia–Ireland Double Tax Agreement (DTA). The dispute arose from payments made by Oracle Australia to Oracle Ireland between 2013 and 2018 for sublicence rights to computer s

Over the past three years, the number of U.S. citizens formally renouncing their nationality has climbed steadily, revealing a structural shift rather than a passing trend. According to the Federal Register’s Quarterly Publication of Individuals Who Have Chosen to Expatriate , 3,260 individuals were listed in 2023, 4,820 in 2024, and already 2,342 through mid-2025. If current trends persist, 2025 will register a significantly high expatriation count. This rise reflects an i

The United States Court of Appeals for the Eighth Circuit’s decision in 3M Company and Subsidiaries v. Commissioner of Internal Revenue (No. 23-3772, October 1, 2025), titled “Eighth Circuit Shields Blocked Income,” represents a pivotal development in international tax jurisprudence. The court reversed the Tax Court’s judgment that had upheld the IRS’s allocation of nearly $23.7 million in additional royalty income which Brazilian law prohibited 3M’s subsidiary from paying.

The Guardian reports a surge in U.S. citizens relocating to Europe following Donald Trump’s return to the presidency. From Barcelona to Dublin, Americans are seeking what they describe as political stability and personal safety. Visa applications to France and Ireland have increased significantly, while European institutions and local governments are launching initiatives to attract skilled U.S. nationals. From a migration perspective, this movement underscores a growing dem

In today's global economy, multinational corporations (MNCs) face unique challenges when it comes to pricing their goods and services...

Taxation is a complex and often contentious issue, especially when it crosses borders. For individuals and businesses operating...