Heather Gething of Herbert Smith Freehills, and Andrew Silverman of McCarthy Tétrault, look at the operation of the general anti-avoidance rules (GAAR) in the UK and Canada, the reason for their introduction, and how they have been and are likely to be applied.
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Section 899 of the ‘one big beautiful’ bill would have spelled disaster for many international investors into the US, but following its shelving, attention turns to the fate of the OECD’s pillars
DLA Piper’s co-head of tax for the US and Latin America tells ITR about her fervent belief in equal access to the law, loving yoga, and paternal inspirations
The US president also unveiled a new 50% levy on copper imports; in other news, a UK wealth tax proposal has been criticised by the Institute for Fiscal Studies
MNEs are increasingly using algorithmic tools in TP. Sahasranshu Dash argues that data ethics should therefore plug directly into the TP design process