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Direct Tax
features sponsored features special focus local insights
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A revised Chapter VII signals a move away from mechanical TP approaches, stressing transaction understanding, functional analysis and context-driven documentation requirements
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HMRC’s growing focus on evidencing tax decisions is shifting attention from technical accuracy to governance, requiring businesses to demonstrate how positions were reached and documented
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In the second instalment of this two-part series, Jayne Stokes takes a practical approach to navigating the capital v revenue question for UK R&D claims for software development, and shares pointers for businesses
Sponsored Features
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Sponsored by DeloitteRonnie Dassen and Jan De Clercq of Deloitte Global outline how agentic AI can support indirect tax teams in managing compliance pressures, improving data quality, and freeing capacity for higher-value advisory work
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Sponsored by DeloitteSameer Nurmohamed, partner, Deloitte Legal Canada
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Sponsored by DeloitteGeorge Ankomah, partner, Tax & Regulatory Services, Deloitte Africa (Ghana)
Special Focus
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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.
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Sponsored by DeloitteGeoff Gill of Deloitte Australia and Andrew Skipsey of Deloitte UK analyse the use of profit split transfer pricing methods in the rapidly evolving banking and commodity trading businesses.
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Sponsored by DeloitteSimón Somohano and Francisco Díaz of Deloitte S-LATAM explain the changes for maquiladoras after the repeal of advance pricing agreements as a compliance option and the implications for Mexico’s competitiveness as a manufacturing location.
Local Insights
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Sponsored by MachadoRenata Colafêmina and Rafaela Calçada da Cruz of Machado Associados comment on how the consumption tax reform could affect the taxation of carbon assets and environmental projects
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Sponsored by Lakshmikumaran & SridharanIndia has amended its GAAR to protect pre-April 2017 investments, but questions remain over application of the Supreme Court’s Tiger Global interpretation, say S Vasudevan, Giridhar Vasudevan, and Romil Hotwani of Lakshmikumaran & Sridharan
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Sponsored by GNV ConsultingFabian Abi Cakra and Aditya Nugroho of GNV Consulting outline how Indonesia’s new pillar two implementation rules establish registration, filing, reporting, and enforcement procedures for in-scope multinational groups under the global minimum tax regime