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Direct Tax
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
January 22, 2025
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Technology is on the way to relieve tax advisers tired by onerous pillar two preparations, says Russell Gammon of Tax Systems -
The BEPS project has seen the arm’s-length principle shift its focus to where human activity takes place, but Leonard Wagenaar questions if this is sustainable in a financialised world
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Anticipating potential changes in tax basis interpretations can help reduce audit risks in tax planning for intercompany equity transfers, says Abe Zhao of FenXun partners
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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
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Sponsored by AKM GlobalAmit Maheshwari and Manish Garg of AKM Global provide a guide to the UAE’s nascent regulatory framework for transfer pricing and offer strategies to ensure compliance and the maintenance of proper documentation
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Sponsored by DeloitteD’Arcy Schieman, partner, indirect tax, Deloitte Canada
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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 MachadoGabriel Caldiron Rezende of Machado Associados highlights the main aspects of the recently approved consumption tax reform regulation
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Sponsored by Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici discuss the latest developments in the OECD International Compliance Assurance Programme and evaluate its role within the framework of tax certainty
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Sponsored by Ritch MuellerJuan José Paullada, Alejandro Santoyo, and José Arturo Pérez of Ritch Mueller explain how foreign investors in Mexico can protect their investments in the face of increasingly stringent tax enforcement measures
