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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

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