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Expert Analysis

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Direct Tax
In the second part of this series, the focus shifts to how taxpayers can manage ongoing risks across the lifecycle of cross-border structures
May 19, 2026
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  • In 1969, 10 countries imposed some type of indirect tax. Today, indirect tax is prolific. More than 160 countries have, plan to have, or are considering some form of indirect tax. Gary Harley, head of indirect tax at KPMG in the UK, explores the rise of indirect taxation.
  • Foreign companies with activity in the US are often surprised that such activity may trigger both federal and state-level tax implications. Joel Walters, Maureen Pechacek and Todd Roberts of PwC US explore how state tax exposure may vary substantially, potentially resulting in significant state tax liabilities even when little to no US federal tax obligations exist.
  • Anne Jorritsma and Marlies Baijer of KPMG in the Netherlands argue that ambiguity in Article 8 of the OECD model treaty means that it no longer follows how the business of international maritime traffic operates.

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