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Cases

View by year:

2025 / 2024 / 2023 ​

2025

Treaties

  • eBay (India) (Interaction between India’s domestic law indirect share transfer provision and the India / Singapore double tax treaty)

  • G Global (Australia) (Constitutional validity of legislation which retroactively overrides double tax treaties)

  • Husky Energy (Canada) (treaty shopping; "beneficial owner" of dividends; Canada / Luxembourg treaty; securities lending arrangement)

  • Malta dual resident company case (Netherlands) (Does company qualify for benefits under Malta / Netherlands double tax treaty?) (in Dutch)

  • Sky High (India) (MLI in respect of India / Ireland treaty does not operate in India because it has not been separately notified; obiter comments on principal purposes test)

  • 3 Sigma Global Fund (India) (does the word, "shares", in India / Mauritius treaty cover derivatives?)

  • Volkswagen AG (India) (notional interest imputed under transfer pricing rules and interest article (Art. 11) in Germany / India double tax treaty)

  • Haworth (UK) (meaning of place of effective management (POEM) in Mauritius / UK double tax treaty)

  • ​Hyosung Corporation (India) (interaction between Indian domestic tax law and Korea / India double tax treaty)

  • VietJet Aviation (UK) (Art. 11(7) (main purpose test) and Art. 22(5) (trade vs. investment activity) in Japan / UK treaty)

  • Hyatt International (India) (Supreme Court's decision on existence of permanent establishment under India / UAE treaty)

  • Methanex (Trinidad and Tobago) (Entitlement to dividend withholding tax exemption under CARICOM treaty)

  • "Interest on Net Equity" case (Netherlands) (Court of Appeal concluded that JCP should be treated as dividends for purposes of Brazil / Netherlands treaty) (in Dutch)

  • Susquehanna (Ireland) (Court of Appeal concluded that Art. 25(4) of Ireland / US treaty could not be used to enable 3 Irish companies to qualify for group relief, because US LLC was not a resident of the US for the purposes of the treaty)

  • Vanguard (India) (meaning of “shares” in capital gains article of India / Ireland treaty)

  • Shah (India) (meaning of “shares” in capital gains article of India / Singapore treaty)

  • Rubis Energie (France) (interaction between France’s CFC rules and France / Mauritius treaty) (in French)

  • Flipkart (India) (treatment under India / US treaty of secondment of employees from US parent company to Indian subsidiary; fees for included services)

  • Legrand (France) (treaty-based dividend exemption; Chile / France treaty) (in French)

  • Samsung (India) (PE under India / Korea treaty; secondment of employees)

  • Royal Bank of Canada (UK) (Art. 6 of Canada / UK treaty)

  • Mashreq Bank (India) (Art. 7(3) of India / UAE treaty; interaction with Indian domestic law)

  • Tiger Global (India) (Supreme Court issues stay order on Delhi High Court decision in favour of taxpayer; capital gains exemption under India / Mauritius treaty)

  • ​SC Lowy (India) (residence and PPT provisions in India / Luxembourg treaty)​

 

Transfer pricing​

  • 3M (US) (Transfer pricing “blocked income” case; application of Loper Bright)

  • Bunge (Spain) (Transfer pricing treatment of cash pooling arrangement) (in Spanish)

  • Medtronic (US) (Court of Appeals for Eighth Circuit rejects Tax Court’s use of unspecified transfer pricing method)

  • Arcomet Towercranes (ECJ) (Are transfer pricing adjustment payments subject to VAT?)

  • Eaton (US) (IRS seeking access to employee performance evaluation records, as part of transfer pricing audit – Court of Appeals for Sixth Circuit

  • Volkswagen AG (India) (notional interest imputed under transfer pricing rules and interest article (Art. 11) in Germany / India double tax treaty)

  • Sony (India) – transfer pricing – royalties – advertising, marketing and promotion expenses – service fees – Delhi Income Tax Appellate Tribunal decision

  • ​Compañía de Transmisión del Mercosur (Argentina) (transfer pricing – long-term loans vs. capital contributions – recharacterization) (Administrative Court of Appeal) (in Spanish)

  • Axa (France) (transfer pricing – interest on intra-group loan) (Paris Administrative Court of Appeal) (in French)

  • Facebook (US) (Tax Court validated 2009 cost sharing temporary regulations and income method; however, Court decided that IRS used incorrect inputs when it applied income method)

  • Menarini (France) (transfer pricing – losses) (Supreme Administrative Court decision) (in French)

  • P. sp. Z o.o. (Poland) (transfer pricing – cost plus method) (Supreme Administrative Court decision) (in Polish)

  • DHL Global Forwarding (Norway) (transfer pricing – persistent losses – service charge) (Court of Appeal decision) (in Norwegian)

  • EET Group (Denmark) (transfer pricing – limited risk distributor – sufficiency of transfer pricing documentation) (Supreme Court decision) (in Danish)

  • Alcoa (Australia) (transfer pricing – transactions with unrelated party / possible bribery: arm’s length price?)

  • Cipla (Kenya) (transfer pricing – circumstances in which adjustments should be made to median in interquartile range) (Tribunal decision)

  • ​Kamenitza (Bulgaria) (transfer pricing: trademark purchase) (in Bulgarian)

  • Sofia Med (Bulgaria) (transfer pricing: service fees) (in Bulgarian)

​

EU​​​​

  • Grupo Massimo Dutti (ECJ) (C-500/24) (Determining the customs value for goods which are sold in successive transactions)

  • Fugro (ECJ) (C-146/24P) (Claim for partial annulment of EU GloBE Directive)

  • BAC (Belgium) (Glitch in Belgian legislation which transposed EU Interest and Royalties Directive) (in Dutch)

  • Arcomet Towercranes (ECJ) (C-726/23) (Are transfer pricing adjustment payments subject to VAT?)

  • Dutch “feeder entity” cases (doc1, doc2) (Netherlands) (2 cases regarding application of anti-abuse provision of dividend withholding tax exemption which implements EU Parent-Subsidiary Directive) (in Dutch)

  • Mediolanum (ECJ) (C-92/24) (does the imposition of Italy’s IRAP on dividends from subsidiaries in other EU Member States breach the EU Parent-Subsidiary Directive?)

  • Tauritus (ECJ) (C-782/23) (Customs duty valuation of goods which have variable price)

  • UTPR case (Belgium) (Constitutional Court refers UTPR in EU’s GloBE Directive to ECJ for review) (in French)

  • Belgium CFC case (ECJ) (C-524/23) (Advocate General Kokott’s opinion on whether Belgium correctly transposed CFC rules in ATAD)

  • Polish property tax case (doc1, doc2) (ECJ) (C-453/23) (circumstances in which tax exemptions are prohibited by EU State aid rules)

  • Genzynski (ECJ) (C-278/24) (personal liability of director for company’s tax debts is compatible with EU law)

  • IRAP (ECJ) (C-92/24 to C-94/24) (does Italy’s IRAP breach EU Parent-Subsidiary Directive?) (ECJ – Advocate General’s opinion)

  • Arcomet Towercranes (ECJ) (Advocate General issues opinion on VAT treatment of transfer pricing adjustments) (in French)

  • Nordcurrent (ECJ) (C-228/24) (application of anti-abuse provision in EU's Parent-Subsidiary Directive)

  • John Cockerill SA (ECJ) (C-135/24) (does Belgium’s dividend received deduction comply with EU Parent-Subsidiary Directive?)

  • Exit tax case (France) (breach of EU principles of legitimate expectations and legal certainty) (in French)

  • Harley-Davidson (ECJ) (297/23P) (relocation of production to Thailand not effective to avoid EU tariffs on imports from US)

  • Volvo (ECJ) (C-436/23) (no breach of freedom of establishment, despite difference in tax treatment between subsidiary and PE)

  • ​Credit Suisse Securities (ECJ) (C-601/23) (does Spain’s dividend withholding tax breach EU free movement of capital?)

​

​Other cases​​

2024

Treaties

  • Cross currency swaps case (Switzerland) (beneficial ownership of interest, where lender had hedged its position with cross currency swaps; Denmark / Switzerland treaty) (in German)

  • Susquehanna (Ireland) (does US LLC qualify as US resident under Ireland / US double tax treaty?)

  • Pilot case (Austria) (English and German versions of Austria / Malta treaty are inconsistent: which version to apply?) (in German)

  • Cook (Denmark) (beneficial ownership; EU Interest and Royalties Directive; Nordic treaty) (in Danish)

  • Hyatt International (India) (determining profits attributable to PE; Art. 7, India / UAE treaty)

  • Tiger Global (India) (India / Mauritius treaty: indirect transfer of shares in India)

  • GE Financial Investments (UK) (UK / US treaty: residence definition; stapled entities; carrying on business)

  • Total Kenya (Kenya) (interaction between Art. 7 ("business profits" article) and Art. 21 ("other income" article) in the France / Kenya treaty)

  • International Management Group (India) ("business profits" article and "fees for technical services" article in India / UK treaty; "make available" condition)

  • Johnson Matthey (India) (taxation of outbound guarantee fee payments; Indian domestic law and India / UK treaty)

  • Burlington Loan Management (UK) (interest withholding tax; Art. 12(5) of Ireland / UK treaty)

  • Bank of Tokyo-Mitsubishi (India) (taxation of bank PE on interest income from intra-entity deposits; Indian domestic law and
    India / US treaty)

  • Cost- and profit-sharing agreement case (Korea) (does agreement cause PE under Italy / Korea treaty?) (in Korean)

  • Royal Bank of Scotland (India) (PE subject to higher income tax rate than domestic company; non-discrimination article in
    India / Netherlands treaty)

  • Siemens (Philippines) (Art. 13 of Germany / Philippines treaty; sale of shares in land-rich companies; use of domestic law to determine whether land-rich)

  • Clifford Chance (India) (“furnishing of services” PE under India / Singapore treaty; counting days)

  • MFN case (Colombia) (“most favoured nation” clause in double tax treaties) (in Spanish)

  • Mitsubishi (India) (non-discrimination articles in India’s treaties with Japan and the US)

  • Branch dividend case (Peru) (domestic law fictions apply to double tax treaty) (in Spanish)

  • Somfy (France) (tax sparing credit in France / Tunisia treaty) (in French)

  • SAIC (India) (embedded software in vehicles: "royalties" definition, China / India treaty)

  • RELX (India) (payments for subscription to online database: "royalties" & "fees for included services" definitions, India / US treaty)

  • Moller Maersk and Safmarine (Pakistan) (“profits from the operation of ships in international traffic”, in Art. 8 of double tax treaties)

  • Fox (India) (does Indian royalty withholding tax apply to broadcasting of “live feed”?; Indian domestic tax law and India / Singapore treaty)

  • Hyatt International (India) (“royalties” and PE definitions in India / UAE treaty)

  • Husky Energy (Canada) (treaty shopping: (1) "beneficial owner" condition in Art. 10, Canada / Luxembourg treaty; (2) GAAR)

​

Transfer pricing

  • Yazaki (Bulgaria) (transfer pricing: start-up losses for new projects) (in Bulgarian)

  • Volkswagen (Argentina) (transfer pricing: extraordinary gain on loan forgiveness – impact on comparability) (in Spanish)

  • Eaton (US) (transfer pricing: IRS succeeds in obtaining foreign employee performance evaluations)

  • Siemens (Kenya) (transfer pricing: use of median in interquartile range)

  • Engie (France) (transfer pricing; business segmentation) (in French)

  • Samsung (India) (transfer pricing; characterisation as contract manufacturer vs. licensed manufacturer)

  • Share-based awards TP case (Ireland) (transfer pricing treatment of share-based awards)

  • BlackRock (UK) (deductibility of interest expense: transfer pricing and “unallowable purpose” rule)

  • ABD Limited (South Africa) (transfer pricing: internal CUP)

  • Singapore Telecom (Australia) (transfer pricing: determination of arm's length interest rate on related party vendor finance)

  • Checkpoint (Kenya) (transfer pricing: can tax authorities make adjustment to median point in arm's length range?)

  • Menarini Diagnostics (France) (can tax authorities use the median in the arm’s length range as the default for a transfer pricing adjustment?)​ (in French)

  • Sumitomo Chemicals (France) (can tax authorities use the median in the arm’s length range as the default for a transfer pricing adjustment?) (in French)​

​

EU​​

  • Weatherford (ECJ) (VAT: acquisition of administrative services within group of companies)
  • Toll manufacturing case (C-475/23) (ECJ) (VAT treatment of provision of asset, free of charge, in toll manufacturing arrangement)
  • X BV (C-585/22) (ECJ) (do Netherlands interest deduction limitation rules breach EU freedom of establishment, in “abusive” situation? Court restricts Lexel case)
  • Russian legal services case (doc1, doc2) (EGC) (are EU restrictions on provision of legal advisory services to Russian government and to entities established in Russia valid?)
  • Legal professional privilege case (ECJ) (Does legal professional privilege permit lawyer to refuse provision of information under DAC6?)
  • UK CFC State aid case (doc1, doc2) (C-555/22 P; C-556/22 P; C-564/22 P) (ECJ) (does "group financing exemption" in UK CFC rules breach EU State aid rules?)
  • Apple State aid case (doc1, doc2, doc3, doc4) (C-465/20 P) (ECJ) (do tax rulings on determination of profits attributable to Irish branches (under Irish domestic law) breach EU State aid rules?)
  • DAC6 case (C-623/22) (ECJ) (Court upholds validity of various provisions in DAC6)
  • VAT group case (C-184/23) (ECJ) (Court confirms long-standing practice that supplies made between members of VAT group are not subject to VAT)
  • "Contribution in kind" VAT case (ECJ) (transfer of property in consideration for issue of shares in acquirer; taxable amount for VAT purposes: nominal value vs. issue price vs. market value of newly issued shares)
  • Free heat VAT case (ECJ) (VAT treatment of the supply of heat, free of charge)
  • Fugro (ECJ) (challenge to Art. 17 of EU GloBE Directive)
  • M-Gbr (ECJ) (VAT case on vouchers)
  • Swedish bank case (EGC) (EU State aid: Sweden’s “risk tax” on large banks)
  • Feudi (ECJ) (VAT: right to deduct input VAT)
  • Employee VAT fraud case (ECJ) (is the employer or employee liable for VAT on fake VAT invoices issued by fraudulent employee?)​ 
  • Fugro (EGC) (challenge to Art. 17, EU GloBE Directive)
  • ​2 Investment Fund cases (case1, case2) (Germany) (EU free movement of capital in Art. 63, TFEU: withholding tax on dividends paid to EU-based investment funds by German companies)
  • FSB (France) (final losses in PE: EU freedom of establishment) (in French)
  • Uruguay case (Netherlands) (EU free movement of capital: credit vs. deduction for Uruguay withholding tax) (in Dutch)

​

Other cases​​

  • Top Cop Shop case (US) (Corporate Transparency Act: preliminary injunction)

  • Mukhi (US) (does IRS have statutory authority to assess penalties for willful failure to file Form 5471?)

  • Refinitiv (UK) (does APA continue to apply after its expiry?)

  • Income Tax (Financial Derivatives) Regulations 2023 case (Kenya) (High Court of Nairobi declares regulations are ultra vires the Income Tax Act, and they are therefore null and void)

  • Finance Act 2023 case (Kenya) (Appeal from Court of Appeal’s decision on constitutional validity of Finance Act 2023)

  • Kilgour (Australia) (can a “special or synergistic value” recognised by only one buyer determine the market value?)

  • ExxonMobil (US) (Development and Production Sharing Agreement for natural gas: characterised as partnership?)

  • Car and General (Trading) case (Kenya) (Kenya’s interest limitation rules: meaning of EBITDA)

  • Foreign exchange gains and losses case (KHO: 2024:103) (Finland) (how are foreign exchange gains and losses treated for purpose of Finland’s interest limitation rules?) (in Finnish)

  • Varian (US) ("effective date" mismatch for section 245A dividends received deduction in respect of section 78 gross-up for foreign tax)

  • Finance Act 2023 case (doc1, doc2) (Kenya) (Court of Appeal's decision rules that Finance Act 2023 is unconstitutional, due to flawed public participation process)

  • Indu Rawat (US) (US source of income rules, as applied to sale of interest in US partnership by non-resident alien individual)

  • John Wiley (Hong Kong) (stamp duty group relief; UK LLP does not qualify)

  • Corner Post (US) (Supreme Court significantly changes time from when statute of limitations runs, for challenging government agency actions (e.g., IRS regulations))

  • Loper Bright (US) (Supreme Court's decision overrules "Chevron deference")

  • PepsiCo (Australia) (royalty withholding tax on "embedded royalties" in purchase price for goods; diverted profits tax; Australian domestic law only)

  • Moore (US) (constitutional validity of mandatory repatriation tax)

  • ECP Kenya (Kenya) (do fund management activities cause a PE for a non-resident fund?; Kenyan domestic law only)

  • Hargreaves Property (UK) (interest withholding tax; is interest recipient “beneficially entitled” to interest?; UK domestic law only)

  • Meyer, Borgman & Johnson (US) (research tax credits; was research performed by taxpayer “funded by … contract”?)

  • Toronto-Dominion Bank (Canada) (GST (i.e., VAT) treatment of loyalty reward program, called Aeroplan)

  • ORA case (Netherlands) (Netherlands tax treatment of convertible bonds issued by French company) (in Dutch)

  • DAC Investment (Canada) (GAAR; sale of shares for capital gain after change of legal domicile from Canada to BVI)

  • Socabelec (Kenya) (withholding tax on deemed interest on interest-free loans)

  • Kwik-Fit (UK) (interest deductions; "unallowable purpose" rule)

  • Farhy (US) (is IRS authorised to assess and collect penalties on taxpayer, under section 6038(b), for willfully failing to file Form 5471?)

  • Disney & IBM (US) (New York franchise tax: interpretation of New York legislation, and dormant Commerce Clause in US Constitution)

  • Bond issuance fees case (Finland) (deductibility of bond issuance fees: subject to interest limitation rules?) (in Finnish)

  • Prudential (UK) (is VAT chargeable on services invoiced after service provider left VAT group?)

  • Mylan (Australia) (debt “pushdown”: Part IVA (GAAR))

  • Minerva (Australia) (Part IVA – i.e., GAAR)

  • Microsoft (US) (should foreign dividends be included in denominator of formula to determine income allocated to California?)

  • National Small Business (US) (Corporate Transparency Act is declared unconstitutional)

  • Patrick Cox Asia (Hong Kong) (source of royalties from trademark licences; impact of use of agent)​

  • Fox (India) (does Indian royalty withholding tax apply to broadcasting of “live feed”?; Indian domestic tax law and India / Singapore treaty)

  • Glencore (Canada) (taxation of merger "commitment fee" and "non-completion fee")​

2023

Treaties

  • Legrand (France) (treaty-based dividend exemption in Chile / France treaty) (in French)

  • Aircraft lease case (Czech Republic) (aircraft lease payments: Art. 8 (aircraft profits) or Art. 12 (royalties) - Czech Republic / Korea treaty) (in Czech)

  • PepsiCo (doc1, doc2) (Australia) (imposition of withholding tax on royalties which are embedded in sale price of goods – Australia / US treaty)

  • Nestlé (India) (MFN clause in India’s treaties)

  • Aircraft maintenance engineer case (Germany) (“fixed place of business” PE under Germany / UK treaty: provision of services at service recipient’s premises) (in German)

  • Delmas (Nigeria) (treaty exemption under Art. 8, France / India treaty: profits of shipping in international traffic)

  • Royalty withholding tax case (Korea) (does Korean withholding tax apply to royalties paid to US resident company for use of US-registered patent?) (in Korean)

  • Algerian PE case (Spain) (apportionment of head office expenses to PE – Algeria / Spain treaty) (in Spanish)

  • Egis Road (Philippines) (late filing of treaty claim)

  • Royal Bank of Canada (UK) (Art. 6 of Canada / UK treaty)

  • GE Financial Investments (UK) (residence definition in UK / US treaty)

  • Hertz (Spain) (payments for customised software: royalties under Spain / US treaty?) (in Spanish)

  • SIS Live (India) (termination of PE – India / UK treaty)

  • Snamprogetti Engineering (Pakistan) (“furnishing of services” PE in Netherlands / Pakistan treaty)

  • “Interest on Net Equity” case (Netherlands) (under Brazil / Netherlands treaty) (in Dutch)

  • 2 “Danish beneficial ownership cases” (Takeda and NTC Parent cases) (Denmark) (exemption from interest withholding tax under EU Interest and Royalties Directive, and under double tax treaties) (in Danish)

  • Treaty shopping case (Peru) (capital gains tax) (in Spanish)

  • Total Oil (India) (dividend distribution tax – Art. 10, France / India treaty)

  • Foreign tax credit case (France) (unusual foreign tax credit provision in France / UAE treaty) (in French)

  • Blackstone (India) (can Singapore tax residency certificate be challenged by Indian tax authorities?)

  • Global Cricket Corporation case (India) (effect of definition of “arise” in Art. 12 of India / Singapore treaty)

  • 2 “Danish beneficial ownership” cases (NetApp and TDC cases) (Denmark) (“look through” approach for beneficial ownership under treaties) (in Danish)

​

Transfer pricing

  • Maersk (Denmark) (transfer pricing: discretionary assessment and determining price on aggregated basis) (in Danish)

  • TP median case (Spain) (should transfer pricing adjustment be made to the median of the arm’s length range?) (in Spanish)

  • Medtronic Ventor (Israel) (business restructuring) (in Hebrew)

  • SAP Labs (India) (TP litigation: availability of appeals to High Court against ITAT’s decision)

  • 3M (US) (validity of “blocked income” transfer pricing regulation) (346 pages!)

​

EU​

  • ​Amazon EU State aid (doc1, doc2) (ECJ) (General Court's 2021 decision is upheld, but its reasoning is rejected)

  • Engie EU State aid (doc1, doc2) (ECJ) (Luxembourg tax rulings on “deduction without inclusion” hybrid mismatch transaction)

  • Apple State aid (doc1, doc2) (ECJ) (Advocate General's opinion)​​

  • Portugal interest case (ECJ) (EU free movement of capital)

  • Spain State aid case (doc1, doc2) (EGC) (legitimate expectation) (case in Spanish; summary in English)

  • Belgium State aid case (doc1, doc2) (EGC) (Belgium’s “excess profits” scheme breaches EU State aid rules)

  • Cabot Plastics (ECJ) (definition of "fixed establishment" for EU VAT purposes)

  • Domestic merger case (ECJ) (applicability of EU Merger Directive to domestic merger) (in Romanian)

  • 2 "Danish beneficial ownership cases" (Takeda and NTC Parent cases) (Denmark) (exemption from interest withholding tax under EU Interest and Royalties Directive, and under double tax treaties) (in Danish)

  • Hedge fund case (Spain) (EU free movement of capital) (in Spanish)

  • Electrabel (doc1, doc2) (Italy) (Beneficial ownership) (in Italian)​

  • LB (doc1, doc2) (European Court of Human Rights) (does publication of "major tax debtors" list breach taxpayers' right to privacy?)​

  • VolkerRail (UK) (EU freedom of establishment – transfer of tax losses)

  • Fenix (doc1, doc2) (ECJ) (VAT treatment of social media platform)

  • Gallaher (ECJ) (do UK’s intragroup asset transfer rules breach EU’s freedom of establishment?)

  • Halet (doc1, doc2) (European Court of Human Rights) (criminal conviction for PwC Luxembourg whistle-blower breaches Art. 10 of European Convention on Human Rights)​

  • Spain State aid case (doc1, doc2) (ECJ) (Spanish tax lease system)

  • Airbnb (ECJ) (EU freedom to provide services – obligations to appoint tax representative)

​

Other cases​

  • GoDaddy (India) (payments for domain name registration: withholding tax under Indian domestic law)

  • ​​PepsiCo (doc1, doc2) (Australia) (Australia / US treaty: withholding tax on embedded royalties; diverted profits tax)

  • Naivas (Kenya) (application of "central management and control" tax-residence test to Mauritius company)

  • Euromoney (UK) (applicability of anti-avoidance provision to third-party transaction)

  • ​Bharti Hexacom (India) (deductibility of annual variable licence fee)

  • SKAT (UK) ("revenue rule")

  • Liberty Global (US) (economic substance doctrine)

  • Participation exemption case (Netherlands) (foreign exchange movement between dividend declaration and payment) (in Dutch)

  • Danone (France) (Constitutional validity of dividend withholding tax imposed on "third country" shareholder with "direct investment") (in French)

  • Vanderstock (Australia) (Constitutional validity of State tax on use of electric vehicles)

  • DST case (Turkey) (Constitutional validity of penalty provision which blocks internet) (in Turkish)

  • TBL Licensing (US) (Outbound transfer of IP by US company, under so-called "drop and check" reorganisation)

  • "Arrangement fee" case (Germany) (interest deduction limitation rules) (in German)

  • Deans Knight (Canada) (applicability of GAAR to plan to effectively transfer tax losses and credits)

  • X BV (Netherlands) (deductible dividends: anti-hybrid rule) (in Dutch)

  • Treaty shopping case (Peru) (Capital gains tax) (in Spanish)

  • Farhy (US) (Taxpayer willfully failed to file Form 5471)

  • Bank of Africa (Kenya) (VAT treatment of interchange fees received by bank)

  • Deliveroo (Netherlands) (employees vs. independent contractors) (in Dutch)

  • X BV case (Netherlands) (interest deductions) (in Dutch)

  • Natixis (France) (carry forward of foreign tax credits by loss company) (in French)

  • Refinitiv (UK) (legal professional privilege) 

  • Bittner (US) (FBAR penalties)

  • Baxter and Energa (2 cases) (Sweden) (capital gains tax treatment of debt restructuring) (in Swedish)

  • ​​Indu Rawat (US) (sale of interest in US partnership)

  • News Corp (UK) (VAT: zero-rating of digital newspaper)

Note: The European Court of Human Rights (ECHR) is not an EU institution. However, for convenience, ECHR cases are included in the EU list.

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