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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...

Moving to a new country can be an exciting adventure. However, it also comes with its own set of challenges, especially when it comes to...