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Tag: economic substance

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The Spanish Tax Agency (AEAT) is redefining how tax risk is assessed. The 2026 Tax Control Plan confirms a clear shift. Tax audits are becoming more targeted, more data-driven, and […]

In January 2026, the Czech Regional Court issued a significant ruling in Czech Republic v. Hitachi Astemo Czech s.r.o. (Case No. 15 Af 10/2023–128), addressing the transfer pricing implications of […]

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