Expert Analysis

The UK Upper Tribunal’s pragmatic approach to anti-abuse provisions will be welcomed by the secondary debt market, say Matthew Greene and Guy Bud of Stewarts

Recent UK case law shows the courts are ready to use a realistic approach to withholding tax exemption issues, writes Michael Alliston, partner at Norton Rose Fulbright

HMRC’s attempts to crack down on fraudulent tax relief claims are well-meaning, but the agency risks penalising genuinely innovative businesses, writes Katy Long of ForrestBrown

Fumiko Mizoguchi, partner, Tax & Legal, Deloitte Japan

Uday Ved, Hetav Vasani, and Snehal Pawar of KNAV India explore how cross-border business restructuring can trigger hidden tax exposures such as exit charges, and examine valuations under evolving global transfer pricing rules

Join ITR and Thomson Reuters on May 28 for the second webinar of a three-part series on e-invoicing and hear how businesses can strategically manage measures such as the VAT in the Digital Age proposal

Ricardo Villalobos of Copper Wolf examines how BEPS pillars one and two reshape global tax rules, potentially affecting domestic systems and closing gaps in multinational corporate tax avoidance

Mikael Jacobsen and Henri Ahtiainen of Skeppsbron Skatt explore how several recent Swedish cases have shed light on the complex distinction between legal and economic ownership of intellectual property in transfer pricing matters

With South Korea expected to intensify its focus on multinationals’ intercompany transactions during tax audits, Yulchon tax partners analyse several transfer pricing-related rulings that could help shape strategy

António Queiroz Martins and Carolina Braga Andrade of Morais Leitão, Galvão Teles, Soares da Silva & Associados explain the application of the rules in Portugal as the country helps lead global tax reform

Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente examine year-end transfer pricing adjustments in light of EU developments and implementation of the OIC 34 accounting standard in Italy

Fernando Matesanz of Spanish VAT Services calls for a rethink of national VAT frameworks after two key judgments that support businesses correcting VAT when commercial transactions are altered, cancelled, or left unpaid