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Direct Tax
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, and rejects protection for indirect transfers and tightening conditions for Mauritius‑based investors claiming DTAA relief
February 11, 2026
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  • Since October 2015, authorities have been reacting to the outcome of the BEPS Project. The implementation of new legislation and adaption of existing regulations to match the new OECD guidelines has already begun to impact multinationals worldwide. The undeniable headline change has been a broad move to implement country-by-country reporting (CbCR); however the other policy that stands out from the crowd is in the area of patent boxes, as Joelle Jefferis explains.
  • Sofia Stavridi, a Queen Mary University of London graduate now working in investment management tax services at a Big 4 firm in the UK, provides a refresher on FATCA and CRS, tracking the latest trends in global exchange of information, exploring the latest tax authority tools in this area and identifying what taxpayers can do.
  • In the seventh in a series of articles on intangibles and finance, Tom Braukmann, Philip de Homont and Alexander Voegele, NERA Frankfurt, show how to implement a profit split system.

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