In a landmark unanimous decision, the Full Court of the Federal Court of Australia in Otsuka Pharmaceutical Co Ltd v Sun Pharma ANZ Pty Ltd [2025] FCAFC 161 (Otsuka FC) held that patent claims ...
The article discusses a recent District Court decision regarding the application of substance over form and other “tax common law” doctrines in a context in which the IRS also proposed adjustments ...
The Chosun Ilbo on MSN
Supreme Court overturns tax ruling, cites substance-over-form principle
The Supreme Court overturned lower court rulings in a lawsuit between the heirs of a wealthy individual and the National Tax ...
Opinion
21don MSNOpinion
Does 'Tiger Global' leave investors confused, or finally put economic substance over legal form?
The Supreme Court has ruled that a Tax Residency Certificate (TRC) is not conclusive proof of eligibility for Double Taxation Avoidance Agreement (DTAA) benefits, reversing a High Court decision. This ...
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