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Direct Tax
features sponsored features special focus local insights
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Chile’s revamped GAAR marks a shift toward structural scrutiny, pushing MNEs to strengthen tax governance, economic substance and compliance strategies
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While the IBS incorporates taxable events previously covered by state and municipal taxes, its governance and operational logic represent a significant departure from the legacy model
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MNEs now face a shift from modelling to execution as the side‑by‑side deal forces tax teams to upgrade systems, harmonise data, and prevent costly pillar two mismatches
Sponsored Features
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Sponsored by CuatrecasasJosé Maria Cabral Sacadura and Vicente Pirrone of Cuatrecasas analyse the Sofina line of CJEU case law and assess when Portuguese withholding tax rules entitle foreign loss‑making companies to reimbursement
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Sponsored by DeloitteOlebogeng Ramatlhodi, Africa indirect tax leader, Deloitte Africa
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Sponsored by DeloitteInterview with Marjolijn van der Wal, partner, indirect tax, Deloitte Netherlands
Special Focus
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Sponsored by EY Central AmericaAntonio Ruiz and Alejandra Arguedas of EY Central America, Panama and Dominican Republic explain how tax, geopolitical factors, and trade agreements shape foreign investment in Central America, offering guidance for companies navigating the region
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Sponsored by DDTC ConsultingDavid Hamzah Damian of DDTC Consulting examines recent procedural changes in Indonesia’s tax disputes process and the Supreme Court’s stance on tax evidence, highlighting key implications for taxpayers facing audits, objections, and appeals
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Sponsored by DeloitteEddie Morris, Josep Serrano Torres, and Jen Breeze of Deloitte compare transfer pricing controversies in the pharmaceutical and automotive sectors, highlighting how DEMPE functions, regulation, and intangibles drive both common themes and sector-specific challenges
Local Insights
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Sponsored by Crowe Valente/Valente Associati GEB PartnersA recent legislative decree sets out highly significant updates to Italy’s international taxation rules. Federico Vincenti and Alessandro Valente of Crowe Valente/Valente Associati GEB Partners provide a guide to the key changes
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Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US discuss the issue of implicit support and a recent IRS advice memorandum addressing transfer pricing for intercompany debt
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Sponsored by KPMG ChinaLewis Lu and John Timpany of KPMG China discuss the potential implementation of the GloBE rules and a minimum top-up tax in Hong Kong from 2025