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Direct Tax
India is signalling flexibility on expat taxation to attract foreign expertise, though employers will need to navigate disclosure, treaty and scope uncertainties
April 21, 2026
features sponsored features special focus local insights
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The BEPS Project, new risk assessment tools, CbCR requirements, and enhanced enforcement actions, among other challenges, are creating unprecedented levels of uncertainty for taxpayers, writes C David Swenson, global leader of PwC’s tax controversy and dispute resolution network. -
Sponsored Features
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Sponsored by DeloitteLisa Zajko, indirect tax partner, Deloitte Canada
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Sponsored by VdAJoão Riscado Rapoula and Hugo Leonardo of VdA analyse the new Construir Portugal scheme, outlining how targeted tax incentives are reshaping the country’s landscape for affordable housing investment and residential real estate
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Sponsored by CuatrecasasJosé Maria Cabral Sacadura and Vicente Pirrone of Cuatrecasas analyse the Sofina line of CJEU case law and assess when Portuguese withholding tax rules entitle foreign loss‑making companies to reimbursement
Special Focus
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Sponsored by YulchonSeveral South Korean transfer pricing cases have established clearer judicial standards emphasising robust comparability analysis and stronger functional and economic evidence. Yulchon tax partners provide practical insights for navigating the heightened requirements
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Sponsored by RSM IndonesiaIchwan Sukardi and T Qivi Hady Daholi of RSM Indonesia examine how geopolitical conflict and economic volatility are reshaping transfer pricing risk and enforcement, with a particular focus on Southeast Asia and Indonesia
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Sponsored by Tax PartnerMonika Bieri and Daniel Schönenberger of Tax Partner use a Swiss lens to examine how workforce mobility is reshaping transfer pricing models, and why the location of key decision‑makers is becoming a critical tax risk
Local Insights
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Sponsored by Tax PartnerStephanie Eichenberger and Victoria Riep of Tax Partner provide a guide to Switzerland’s securities transfer tax for domestic and foreign investors, explaining when it is triggered and how to mitigate unexpected tax consequences
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Sponsored by CuatrecasasAndré Areias and Raquel Santos Ferreira of Cuatrecasas scrutinise Portugal’s use of increased municipal property tax on vacant properties and question whether extreme rate multipliers and weak procedural safeguards can withstand constitutional scrutiny
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Sponsored by MFA Legal & TechSamuel Fernandes de Almeida and Ana Rita Carvalho of MFA Legal & Tech explain how a Portuguese binding ruling fuels the emerging dispute with Spain over non-habitual tax residents
