Dentons has successfully represented Sev.en EC, a.s., a member of the Czech Coal group, before the Supreme Administrative Court of the Czech Republic in what the firm calls "extraordinary litigation" related to the reimbursement of gift tax from the Czech state that was imposed on the free carbon dioxide emission allowances in 2011 and 2012 in breach of EU law.
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Ukraine has made a great leap forward in the development of transfer pricing rules since the concept of “controlled transactions” was first introduced in the Tax Code in 2013. These transfer pricing rules have been amended in recent years and Ukrainian taxpayers are likely to face many new issues on the subject in 2017.
The growing interdependence of world economies, driven by the reduction and removal of trade barriers, cheaper transport and communication costs, and increased use of the Internet (facilitating easier access to foreign markets), as well as by the growth of multinational corporations, has resulted in unprecedented cross-border trade and capital flows. At the same time, it has also opened up new opportunities for multinationals to reduce their profit in high-taxed jurisdictions by exploiting gaps and mismatches in domestic and international tax rules to artificially shift it to low-taxed countries (or tax havens).