Ramiro Morales

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 case is significant...

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 legal and trade...

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 nevertheless qualify...