On September 25, 2025, Perrigo v. U.S. was decided, marking a significant win for the taxpayer, particularly in the Court’s finding regarding economic substance and risks. The Federal Judge in the…
The Indian Supreme Court has again expressed its views on the meaning of PE in the context of franchise arrangements for the operation of hotels in India under a well known brand. It also reflects a…
I am delighted to see that my post on value creation has stimulated discussion on the fundamental thinking about international taxation. See the posts of my friends and colleagues Werner Haslehner…
