AGPLAW | A.G. Paphitis & Co. LLC’s Post

Recent Korean TP precedents: insights into strategic tax audits and appeal preparation With Korea expected to take a more aggressive approach to auditing, tax partners from Yulchon LLC analyse four transfer pricing-related rulings that provide guidance for multinationals http://spr.ly/6044kqYj2

ECJ Landmark Tax Ruling in case of Apple Inc. In a landmark ruling, the European Court of Justice (ECJ) has overturned Apple's previous €13 billion tax victory against the European Commission, marking a pivotal moment in EU tax law. The ECJ ruled that Ireland granted illegal state aid to Apple through preferential tax treatment, allowing the company to attribute the majority of its European sales profits to "head offices" that existed only on paper, resulting in an effective corporate tax rate of just 0.005% in 2014 on Apple's European profits. The ECJ's decision emphasizes that profit allocation between a company's branches should consider only the functions, assets, and risks within those specific entities, not the activities of other group companies. This ruling significantly strengthens the European Commission's ability to challenge corporate tax arrangements under state aid rules, even without harmonized EU tax laws. Multinational companies with similar structures may need to reassess their tax positions, as this case highlights the tension between national tax sovereignty and EU efforts to ensure fair corporate taxation across the bloc.

In recent years, there has been an increase in disputes between companies and tax authorities. Our specialists Peter Moons and Pierre-Antoine Klethi discuss in an interview published by Paperjam and Delano the trends and developments in Luxembourg tax controversy and the impact of the CJEU state aid judgments siding with Fiat and Amazon 👉 https://lawand.tax/3SPs3mb 🔊 The article is available in both English and French! #lawandtax #luxembourg #tax #europe #litigation

International Tax is a core specialty of RKCA & Co. LLP. In this article, we have demystified the basic of international tax: https://lnkd.in/d6ZPZH5E

A big #thankyou to Denisa Palková for her very interesting article on The Importance of #Double #Taxation #Treaties. Kreston Global #international #taxation Calling all of our #kreston #tax #team to be the next expert to share their thoughts. #getintouch

Yulchon International Tax Team, Assemble! Thanks to ITR, our team's professionals recently shared some transfer pricing insight. Surprisingly, one of the most famous tax focused news agencies in Korea translated the overall content into Korean. https://lnkd.in/gVqNKhBM #yulchon, #internationaltax, #transferpricing, #korea

Singapore will impose new corporate #taxes in 2025 to abide by a global initiative aimed at tackling #tax avoidance by multinational enterprises (MNEs). The initiative aims to ensure a global minimum effective tax rate of 15% for large MNEs.

Mexican Tax regulations. Worldwide, one of the most complicated. Axosnet is the solution to grow your business in Mexico and comply with tax regulations.

Sharing some thoughts in #Paperjam and #Delano together with Peter Moons as regards #Luxembourg tax #litigation evolution and trends!

Does McDonald's Avoid Corporate Tax in No-Tax Countries? Answers: https://lnkd.in/gce2YqTj #CorporateTax #BusinessStrategy #TaxHavens #McDonalds Hey there! 🤔 Let’s dive into an interesting topic that often sparks debate. So, picture this scenario: Imagine a country with no corporate tax. Now, let’s say McDonald’s decides to open a division there. The big question is: Does McDonald’s have to pay any corporate tax on this new division? 🤷♂️ Here’s my take on it: If a country truly doesn’t impose any corporate tax, then yes, McDonald’s wouldn’t pay corporate tax on profits made from that division. 💰 This could be a huge motivation for multinational corporations to set up shop in tax-free zones. However, it’s worth noting that companies must comply with local laws and regulations even if there’s no corporate tax. 💭 Food for thought: While a lack of corporate tax can be inviting for businesses, it raises questions about how a country funds public services and infrastructure without those tax revenues. I can imagine it gets a bit complicated when it comes to international tax laws, too. Each country has its own regulations regarding profits, and sometimes compani...