Coca-Cola announced that it would appeal to the Eleventh Circuit Court of Appeals, based in Atlanta, the Tax Court’s final entered decision of August 2, 2024, in favor of the IRS’ determination of $9 billion of transfer pricing adjustments and the validity of the IRS’ blocked income regulations.[1] The 240-page Coca-Cola 2020 Tax Court decision[2 ..read more

Highlights & Insights on European Taxation Please find below a selection of articles published this month (September 2024) in Highlights & Insights on European Taxation, plus one freely accessible article. Highlights & Insights on European Taxation (H&I) is a publication by Wolters Kluwer Nederland BV. The journal offers extensive information on all recent developments in European Taxation in the ..read more

After the silent collapse of Pillar One earlier this summer, as it now seems, the question as to what’s next seems to be moving up business agendas and political agendas. On an informal meeting of tax practitioners from business and consultancy in Rotterdam, the Netherlands, on 24 September 2024, the author of the current blog ..read more

Introduction The Indian GAAR (Chapter X-A of the Income-tax Act, 1961 [‘the Act’])) was introduced in the Finance Act 2012 and came into effect on April 1, 2017. Prior to the introduction of GAAR, Indian courts have dealt with tax avoidance cases and have developed principals, also referred to as judicial doctrine to combat arrangements ..read more

The terms of reference (ToR) adopted by the Ad Hoc Committee[i] will be submitted to the UN General Assembly and voted during its 79thth session – taking place from 10 to 24 September 2024 in New York. If these terms of reference are adopted, the negotiating committee will be expected to submit a final text ..read more

Highlights & Insights on European Taxation Please find below a selection of articles published this month (August 2024) in Highlights & Insights on European Taxation, plus one freely accessible article. Highlights & Insights on European Taxation (H&I) is a publication by Wolters Kluwer Nederland BV. The journal offers extensive information on all recent developments in European Taxation in the ..read more

Highlights & Insights on European Taxation Please find below a selection of articles published this month (July 2024) in Highlights & Insights on European Taxation, plus one freely accessible article. Highlights & Insights on European Taxation (H&I) is a publication by Wolters Kluwer Nederland BV.   The journal offers extensive information on all recent developments in European Taxation in ..read more

Highlights & Insights on European Taxation Please find below a selection of articles published this month (June 2024) in Highlights & Insights on European Taxation, plus one freely accessible article. Highlights & Insights on European Taxation (H&I) is a publication by Wolters Kluwer Nederland BV.   The journal offers extensive information on all recent developments in European Taxation in ..read more

Highlights & Insights on European Taxation Please find below a selection of articles published this month (May 2024) in Highlights & Insights on European Taxation, plus one freely accessible article. Highlights & Insights on European Taxation (H&I) is a publication by Wolters Kluwer Nederland BV.   The journal offers extensive information on all recent developments in European Taxation in ..read more

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Vladimir Starkov, The Need for Plan B: Comments As of mid-July 2024, the Multilateral Convention (MLC) on Amount A seems to have received a lacklustre response from the majority of stakeholders, despite the extensive ..read more