Courts Worldwide Diverge in Applying the Principal Purpose Test

Although over 100 countries have signed the Multilateral Instrument, courts around the world have diverged in their application of the Principal Purpose Test, says Christos A. Theophilou of STI Taxand. [...]

By |2025-01-29T11:49:30+00:00November 4th, 2024|Publications|

Pillar Two of the Inclusive Framework on BEPS (Global Minimum Taxation of the OECD – OCDE)

We are proud to announce that Christos A. Theophilou, Partner at STI Taxand, has contributed to the newly published book, Pillar Two of the Inclusive Framework on BEPS: A Problem-Solving [...]

By |2024-12-22T16:01:29+00:00October 1st, 2024|Publications|

Trademark Transfers & Transfer Pricing: Recharacterization & Licensing

Christos A. Theophilou of STI Taxand analyzes a Polish legal dispute over cross-border licensing and its transfer pricing implications amid evolving laws. Poland vs. K.P., adjudicated on October 3, [...]

By |2024-05-29T17:55:09+00:00May 13th, 2024|Publications|
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