Asia-Pacific
Grant Thornton advanced plans to integrate its Australian firm into its US arm, as tax developments spanned law firm hires, aviation levies and digital services taxes
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
Significant changes include an update to profit markers and an alteration to how an ‘inbound distributor’ is defined
India is signalling flexibility on expat taxation to attract foreign expertise, though employers will need to navigate disclosure, treaty and scope uncertainties
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Sponsored by Lakshmikumaran & SridharanSeveral key rulings clarify the taxation of cross-border payments as royalties with respect to ‘information concerning industrial, commercial or scientific experience’, say S Vasudevan, Prachi Bhardwaj, and Prakhar Pandey of Lakshmikumaran & Sridharan
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Sponsored by DLA Piper AustraliaKelvin Yuen and Suhani Mehra of DLA Piper Australia examine a Full Federal Court decision denying deductions for undocumented intragroup service fees, and the risks of relying on inferred contracts in related-party transactions
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Sponsored by HLB ThailandPaul Ashburn, Radapak Arthapridi, and Anna Selina De Vera of HLB Thailand explain how the update to the Commentary on Article 5 clarifies when employees’ homes may create a taxable permanent establishment in the country
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