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Direct Tax
features sponsored features special focus local insights
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From pillar two and amount B to Apple’s headline EU Commission dispute, Martin Bonner and Yiwen Ping of Kreston Global argue that 2024’s key TP developments will inform 2025
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In-house teams that want a balance of internal control and external expertise for pillar two should seriously consider co-sourcing models, Russell Gammon of Tax Systems argues
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Norton Rose Fulbright highlights a Brazilian investment fund as a practical example of how new Dutch tax rules will require significant attention from foreign companies
Sponsored Features
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Sponsored by DeloitteInterview with Dr Alexander Linn, partner, business tax
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Sponsored by DeloitteInterview with Bernard Mofokeng, head of tax controversy (South Africa), Deloitte Africa tax and legal
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Sponsored by CuatrecasasLiliana Piedade and João Filipe Rodrigues of Cuatrecasas argue for a substantive interpretation of Portugal’s stamp duty exemption on guarantees provided by financial institutions, credit institutions, and similar entities to counterparts of an identical nature
Special Focus
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Sponsored by DeloitteShaun Austin, Darcy Alamuddin, and Ryan McMahon of Deloitte analyse the feedback from the 2024 Deloitte transfer pricing controversy survey, highlighting key trends in the transfer pricing controversy space
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Sponsored by Kambourov & Partners Tax ConsultingDennitsa Dimitrova of Kambourov & Partners Tax Consulting highlights a significant tax risk in M&A transactions involving telecommunications operators and suggests what steps should be taken during the due diligence process
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Sponsored by DeloitteMariusz Każuch, Inka Traeger, and Conrad Marburg of Deloitte consider tax authorities' recharacterisation of intercompany transactions through drawing on recent practice in Poland and Germany, and suggest proactive measures global businesses can take
Local Insights
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Sponsored by Ritch MuellerOscar López Velarde and Samantha Oseguera of Ritch Mueller examine the uncertainty surrounding Mexico’s 4.9% withholding tax on interest payments to US banks and its impact on cross-border credit amid shifting Mexico–US political dynamics
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Sponsored by KPMG SwedenAnna Valdemarsson and Heléne Markström of KPMG Sweden welcome the suggested changes in the recently published review, which are designed to enhance the use of expert tax relief in the country
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Sponsored by HLB ThailandPaul Ashburn and Anna Selina De Vera of HLB Thailand say the decree underlines the country’s commitment to pillar two implementation as Thailand aims to become one of the first two Southeast Asian countries to join the OECD