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Direct Tax
Foreign companies operating in Libya face source-based taxation even without a local presence. Multinationals must understand compliance obligations, withholding risks, and treaty relief to avoid costly surprises
December 18, 2025
features sponsored features special focus local insights
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While UN proposals to shift airline taxation from a residence-based system to a source-state one are not set in stone, ex-British Airways CEO Willie Walsh warns they would increase costs and complexity -
Experts from law firm Kennedys outline the key tax disputes trends set to define 2026, ranging from increased enforcement to continued tariff drama and AI usage
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Defending loss situations in TP is not about denying the existence of losses but about showing, through proactive measures, that the losses reflect genuine commercial realities
Sponsored Features
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Sponsored by CuatrecasasA recent ruling curbs formalistic proof requirements in EU cross-border pension fund taxation while strengthening the substance over form and ‘equality of arms’ concepts, say João Rodrigues, Liliana Piedade, and Francisco Ludovino Reis of Cuatrecasas
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Sponsored by CMSTax authorities in Europe are stepping up their transfer pricing focus. A podcast held by ITR in collaboration with CMS explores what multinational enterprises can do to mitigate risk
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Sponsored by CMSTaxpayers may have to refine their approach in staving off tax controversy. A podcast held by ITR in collaboration with CMS explains why audits and tax litigation may never be the same
Special Focus
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Sponsored by DeloitteAriel Krinshpun and James Mahon, III of Deloitte US and George Galumov of Deloitte Switzerland analyse two areas of intercompany financing arrangements as transactions come under increasing scrutiny from tax authorities.
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Sponsored by DeloitteAaron Wang of Deloitte China and Iva Georgijew of Deloitte Poland set out the key questions when limited risk and low-risk distributors incur losses, and consider the challenges presented in several common scenarios.
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Sponsored by DeloitteEdward Morris of Deloitte UK and Sobhan Kar of Deloitte India question whether the adage that mutual agreement procedures work, but too slowly, is still correct.
Local Insights
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Sponsored by SumersonNicolas Duboille and Mathis Rossignol of Sumerson analyse the far-reaching implications of a French Supreme Administrative Court decision clarifying the application of Article 123 bis of the General Tax Code
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Sponsored by EY RomaniaOvercoming new Romanian limits on deductibility for cross-border affiliate transactions through APAsAdrian Rus and Georgiana Bizdrigheanu of EY Romania explain how advance pricing agreements can help taxpayers navigate Romania’s new deductibility limitations and improve predictability and efficiency
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Sponsored by EY RomaniaEmanuel Băncilă of Băncilă, Diaconu și Asociații SPRL, part of the EY Law global network, outlines practical strategies for Romanian taxpayers facing 'surprise' inspections and procedural limits
