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Direct Tax
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From pillar two and amount B to Apple’s headline EU Commission dispute, Martin Bonner and Yiwen Ping of Kreston Global argue that 2024’s key TP developments will inform 2025
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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
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Norton Rose Fulbright highlights a Brazilian investment fund as a practical example of how new Dutch tax rules will require significant attention from foreign companies
Sponsored Features
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Sponsored by Thomson ReutersGain essential insights into continuous tax controls by joining ITR and Thomson Reuters on April 30 for the first webinar of a three-part series on streamlining e-invoicing compliance in a digital-first world
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Sponsored by RSM IndonesiaBusinesses must embrace a new tax paradigm with Indonesia’s adoption of pillar two. Ichwan Sukardi and T Qivi Hady Daholi of RSM Indonesia explore the impact on compliance, transfer pricing, and tax incentives
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Sponsored by DeloitteSenior Deloitte tax practitioners examine how international remote work is reshaping tax policy and explore the challenges businesses and governments face in navigating corporate, individual, and social security taxation
Special Focus
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Sponsored by Skeppsbron SkattMikael Jacobsen and Henri Ahtiainen of Skeppsbron Skatt explore how several recent Swedish cases have shed light on the complex distinction between legal and economic ownership of intellectual property in transfer pricing matters
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Sponsored by YulchonWith South Korea expected to intensify its focus on multinationals’ intercompany transactions during tax audits, Yulchon tax partners analyse several transfer pricing-related rulings that could help shape strategy
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Sponsored by Tax PartnerMonika Bieri and Caterina Colling Russo of Tax Partner discuss a Swiss court ruling concerning the use of multi-year margin averaging in transfer pricing adjustments and suggest several steps that could help ensure compliance
Local Insights
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Sponsored by Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Andrea Mirabella of Gatti Pavesi Bianchi Ludovici comment on a judgment regarding the withholding tax exemption for outbound interest on financing received indirectly by foreign investment funds as beneficial owners
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Sponsored by Alma LEDFrancesco Di Bari of Alma LED explains how an Italian Supreme Court ruling marks a pivotal shift in the tax treatment of interest on indirect lending, restoring key exemptions for qualified foreign institutional investors
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Sponsored by KPMG SwedenNiklas Elofsson and Vsevolod Konyshev of KPMG Sweden draw on their experience to explore how successful tax functions implement structured transformation strategies to manage complexity and deliver long-term value