GMT
Reframing a Permanent Establishment Allegation
We defended a prominent multinational consumer electronics company in a permanent establishment (PE) tax crime case, proving misidentification and reframing the issue as administrative, leading to a settlement without prosecution.
More Stories
Testing the Limits of Transfer Pricing Rules
We represented a South Korean multinational logistics company in a TP dispute over a domestic restructuring, convincing the court that no compensation was required for the spin-off of its operations.
Revenue Recognition Under Scrutiny
We represented a Finnish multinational vertical transport provider in a dispute on revenue recognition, proving that percentage-of-completion was appropriate, leading the court to fully overturn the tax authority’s correction.
