[{"pubDate":"Mon, 24 Mar 2025 10:22:04 +0100","titre":"Lowy: the first PPT-case","url":"https://kluwertaxblog.com/2025/03/24/lowy-the-first-ppt-case/","id":2003536,"description":"On December 30th of last year, the Indian Income Tax Appellate Tribunal was the first “quasi judicial institution” to apply the PPT to a treaty-shopping arrangement.[1] The case concerned a dispute between a Luxembourg-based holding company, SC Lowy, and the Indian tax authorities. Facts of the case The Luxembourg holding company, SC Lowy, is owned... Continue","source":"Kluwer International Tax Blog"},{"source":"Kluwer International Tax Blog","description":"This blog post was first published on the Kluwer Competition Law Blog.   On September 10, 2024, the European Court of Justice (ECJ or Court) sided with the European Commission (Commission) and ruled that two Irish subsidiaries of Apple Inc. received unlawful state aid from Ireland in the form of a tax advantage (Case C-465/20... Continue","id":1685685,"titre":"Your Homework Will Be Graded: The ECJ’s Apple Decision and Its Implications for International Tax","url":"https://kluwertaxblog.com/2024/11/07/your-homework-will-be-graded-the-ecjs-apple-decision-and-its-implications-for-international-tax/","pubDate":"Thu, 07 Nov 2024 16:05:01 +0100"}]