Introduction
The present contribution aims at discussing two fundamental concepts often coming into play in the analysis of transactions between associated enterprises involving intangible property:…
Back in 2015, my first ever blog asked Does the UK Diverted Profits Tax help or hurt BEPS? Whatever the answer, the level of complexity and the challenges it brought to UK cross-border taxation…
Bram Markey – EMEA Leader Tax Controversy & Dispute Resolution at PwC Belgium
Raphaël Devroye – Transfer Pricing Manager at PwC Belgium
In a recent judgement[1], the Belgian Court of Appeal of Ghent…
