Automatic injunctive relief in German patent law shifts bargaining power between a patentee (plaintiff) and a defendant to the patentee. This will impact both settlement behaviour and the settlement payment....
The Marketing Intangible Proposal presented in the OECD’s Public Consultation Document (released on February 13, 2019) does not provide taxpayers and tax administrations with a clear guidance on the potential...
The newly released public Discussion Draft “BEPS ACTIONS 8 – 10, Financial transactions” (the “Discussion Draft”) provides additional guidance to taxpayers and tax administrations on how to deal with controlled...
The proposed draft Transfer Pricing guidelines released by the Italian Ministry of Economy and Finance (MEF) on 21 February 2018 fail to provide a clear guidance on how to evaluate...
The newly released public Discussion Draft “Implementation Guidance on HTVI” (the “Discussion Draft”) aims at tackling the information asymmetry between the taxpayer and the tax administration. In particular, the tax...
The Discussion Draft “Revised Guidance on Profit Splits” released by the OECD 22 June 2017 does not provide taxpayers and tax administrations with a thorough and univocal guidance on when...