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Direct Tax
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While it may be difficult to change some of the individuals in your team, Keith Brockman believes it is possible to develop their skills in areas essential to future success, such as negotiation and leadership.
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The framework for analysing intercompany transactions involving intangibles is examined by Hendrik Blankenstein and Caterina Colling Russo at Tax Partner AG – Taxand Switzerland. Does the new DEMPE analysis benefit MNEs and tax authorities or simply confuse matters, resulting in an increase of intangibles-related disputes?
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BEPS aims to prevent aggressive profit-shifting strategies to better align transfer pricing outcomes with value creation. In this paper, Dale Hill, a partner at Gowling WLG, examines BEPS’s application to the transfer pricing aspects of intangibles and the impact on tax-motivated IP migration strategies.
Sponsored Features
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Sponsored by BDO IndiaJoin ITR for a free webinar on February 4 as senior tax practitioners from BDO India analyse a highly significant ruling by the Indian Supreme Court
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Sponsored by DeloitteInterview with Candy Ye Tang, tax and business advisory leader, Deloitte China
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Sponsored by DeloitteInterview with Adham Hafoudh, partner, Tax & Legal, Deloitte Czech Republic
Special Focus
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Sponsored by EY Central AmericaAntonio Ruiz and Alejandra Arguedas of EY Central America, Panama and Dominican Republic explain how tax, geopolitical factors, and trade agreements shape foreign investment in Central America, offering guidance for companies navigating the region
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Sponsored by DDTC ConsultingDavid Hamzah Damian of DDTC Consulting examines recent procedural changes in Indonesia’s tax disputes process and the Supreme Court’s stance on tax evidence, highlighting key implications for taxpayers facing audits, objections, and appeals
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Sponsored by DeloitteEddie Morris, Josep Serrano Torres, and Jen Breeze of Deloitte compare transfer pricing controversies in the pharmaceutical and automotive sectors, highlighting how DEMPE functions, regulation, and intangibles drive both common themes and sector-specific challenges
Local Insights
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Sponsored by Saleh, Barsoum & Abdel Aziz – Grant Thornton EgyptRabie Morsy and Ahmed Khalifa of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt analyse the amendments and guidance, focusing on construction, commodities, exemptions, and practical compliance implications for businesses
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Sponsored by Saleh, Barsoum & Abdel Aziz – Grant Thornton EgyptRabie Morsy and Karim Adel of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt assess the package’s impact on dispute resolution, investment structures, and administrative efficiency
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Sponsored by Spanish VAT ServicesThe ruling clarifies that Spain cannot restrict VAT exemptions for general services directly necessary to independent groups’ exempt activities, says Fernando Matesanz of Spanish VAT Services