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Direct Tax
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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
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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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Global tax rules are changing, and changing rapidly. The final reports on the Base Erosion and Profit Shifting (BEPS) Action Plan have been released by the Organisation for Economic Cooperation and Development (OECD) and endorsed by the G20. These reports on the 15 BEPS Action Points recommend significant changes in international tax laws and treaties. Due to the unique global alignment on the matter, BEPS is the most comprehensive change in international taxation in history. Attention has turned to the actions that are being taken by countries in response to these recommendations.
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There is no such thing as a quiet year for China's tax system.
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The focus of many of the articles in this guide on issues tied to the multilateral efforts to counter tax base erosion and profit shifting (BEPS) shows that taxpayers across Latin America are keeping a close watch on global developments.
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