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Case C-603/24, Stellantis Portugal , pending before the Court of Justice of the European Union, sits at the intersection of two regimes that frequently coexist in multinational groups but rarely align seamlessly: transfer pricing and value added tax. The dispute concerns whether post-year transfer pricing adjustments, made to ensure arm’s length outcomes for corporate income tax purposes, must also retroactively alter the VAT taxable amount of intra-group transactions. The ca

In recent months, the United States has come under sustained international scrutiny for its positions on global taxation and energy-related fiscal measures. Between its continued non-implementation of the OECD/G20 Pillar Two global minimum tax, its rejection of a United Nations–backed global carbon tax, and adverse rulings at the World Trade Organization regarding U.S. clean energy tax credits, U.S. policy choices are increasingly perceived as misaligned with multilateral le

Introduction On 16 January 2026, the United States Court of Appeals for the Fifth Circuit issued a landmark decision in Sirius Solutions, L.L.L.P. v. Commissioner of Internal Revenue , fundamentally rejecting the Internal Revenue Service’s recent approach to self-employment taxation of limited partners. The dispute concerned the interpretation of section 1402(a)(13) of the Internal Revenue Code and whether limited partners who participate in management or operations may never

Corporate taxation continues to be a decisive factor for multinational investors assessing jurisdictional attractiveness. While statutory rates remain important, international reforms most notably the OECD/G20 Pillar Two global minimum tax framework have altered how low-tax European jurisdictions structure their regimes. In this evolving landscape, investors increasingly prioritise effective tax burden, regulatory stability, compliance with international norms, and access to

On 27 January 2026, the European Union and India concluded negotiations on a landmark Free Trade Agreement (FTA), publicly characterized as the “mother of all deals.” The agreement represents the largest free trade arrangement ever concluded by either party and marks a decisive shift toward a rules-based, strategic economic partnership. Its relevance for businesses is immediate and concrete, particularly in the areas of customs liberalisation, rules of origin, and global valu

Introduction The judgment of the Court of Justice of the European Union in Case C-39/23, concerning the compatibility with Article 63 TFEU of national tax rules that subject dividends paid to foreign public pension institutions to withholding tax while exempting dividends received by domestic public pension funds. The analysis focuses on three interrelated legal questions: whether such differential treatment constitutes a restriction on the free movement of capital, how the o

Introduction In recent years, the California Legislature has examined proposals to introduce a state-level wealth tax aimed at the state’s highest-net-worth individuals. Although no comprehensive wealth tax has yet been enacted, the repeated introduction of such bills by the California Legislature has generated substantial legal, fiscal, and behavioral debate. The issue is significant because California already maintains one of the highest marginal income tax rates in the Uni

On the 16 of January 2026, EU and Mercosur sign a historic and ambitious partnerships. Shortly after the European Parliament voted narrowly to refer the recently signed free trade agreement between the European Union and the Mercosur bloc of South American countries (Argentina, Brazil, Paraguay and Uruguay) to the Court of Justice of the European Union for legal review, temporarily postponing its ratification. The referral reflects institutional concerns regarding treaty comp

Navigating the complex world of international tax and trade requires a clear understanding of customs regulations and tax implications. As businesses and individuals engage in cross-border transactions, the interplay between international tax laws and customs duties becomes increasingly significant. This article explores the critical aspects of international tax and trade, focusing on customs and tax implications that affect expatriates, individuals, and corporations with int

Navigating the complexities of international tax law can be a daunting task. Whether you are an expatriate, an individual with overseas investments, or a corporation operating across borders, understanding the nuances of tax regulations in multiple jurisdictions is essential. I have found that hiring an international tax lawyer is not just a precaution but a strategic move that can save significant time, money, and stress. International tax law involves a web of treaties, reg

On 10 December 2025, the Paris Administrative Court of Appeal delivered an important decision concerning the deductibility of intra-group trademark royalties within a French tax-integrated group headed by ArcelorMittal France. The dispute arose following a tax audit of its French subsidiaries, Industeel Creusot and Industeel Loire, which had paid royalties to their Luxembourg parent, ArcelorMittal SA. The decision is significant because it reaffirms that, for transfer pricing

As of late December 2025, several European and UK jurisdictions have enacted tax measures that will take effect in 2026. These reforms significantly enhance the attractiveness of investing in certain European member states and the UK. They should be viewed as part of a broader, coordinated effort to strengthen Europe’s position in global capital markets. This comes at a time of intensified competition for private investment, entrepreneurial talent, and innovation funding. In

Introduction In May 2025, the Danish National Tax Tribunal (Landsskatteretten) issued a significant transfer pricing decision on the valuation of intellectual property in an intragroup restructuring. The case concerned the transfer of a bundle of intangible assets from a Danish company to a newly established group entity, followed by a conversion of the Danish company into a routine sales and service provider. The dispute focused on whether the agreed transfer price for the i

Overview of the Resolution On 12 December 2025, the Court of Appeal of Tanzania dismissed Civil Appeal No. 182 of 2025, confirming that head office costs allocated to a Tanzanian permanent establishment are not deductible unless the taxpayer strictly complies with the substantive requirements of domestic tax law. The Court upheld the decisions of the Tax Revenue Appeals Board and the Tax Revenue Appeals Tribunal, thereby consolidating a consistent judicial position on the lim

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