On December 2 2010 the Brazilian government granted the exclusion of Spanish holding companies (ETVEs) from its grey list of privileged tax regimes. Isabel Bertoletti, Fabíola Costa Girão and Henrique de Freitas Munia e Erbolato of Machado report on the run-up to the removal.
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India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
ITR sat down for a pre-event interview with Tim Zech, WTS Germany, and Jeff Soar, WTS UK, keynote speaker at next week’s ITR AI in Tax Forum 2026 in London
India is signalling flexibility on expat taxation to attract foreign expertise, though employers will need to navigate disclosure, treaty and scope uncertainties