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Direct Tax
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Luiz Felipe Centeno Ferraz, Alessandro Amadeu da Fonseca and Antonio Carlos Marchetti Guzman of Mattos Filho Veiga Filho Marrey Jr e Quiroga Advogados analyse the recently updated Brazilian transfer pricing rules and offer insight into what it means for multinational taxpayers.
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US taxpayers breathed a collective sigh of relief in April when the Supreme Court delivered its verdict in Home Concrete which stated that the Internal Revenue Service (IRS) was not permitted to use an extended six-year statute of limitations period to investigate overstatements of basis. But there was a broader issue at stake in the case – the IRS’s ability to issue regulations and apply them retroactively. Joe Dalton explores the wider implications of Home Concrete and why US taxpayers will be hopeful the ruling will diminish the IRS’s arsenal in avoidance cases.
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The eighth European Tax Awards were notable for the in-house awards that went to companies with media and entertainment roots
Sponsored Features
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Sponsored by insightsoftwareJoin Grant Thornton and insightsoftware on April 23 for a free ITR webinar exploring how flexible tax software aligns with your existing processes, enabling smoother adoption, integration, and phased implementation across complex organisations
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Sponsored by BDO IndiaJoin ITR for a free webinar on February 4 as senior tax practitioners from BDO India analyse a highly significant ruling by the Indian Supreme Court
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Sponsored by DeloitteInterview with Candy Ye Tang, tax and business advisory leader, Deloitte China
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 Steadfast Business ConsultingMithilesh Reddy of Steadfast Business Consulting outlines how the qualified domestic minimum top-up tax is reshaping multinational tax planning, compliance, and strategic operational structures in the UAE
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Sponsored by Morais Leitão, Galvão Teles, Soares da Silva & AssociadosMaria Gouveia of Morais Leitão, Galvão Teles, Soares da Silva & Associados examines the most widespread misconceptions surrounding the regime, clarifying its tax deferral mechanism, effective rates, eligibility criteria, and scope
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Sponsored by Garrigues SpainRafael Calvo Salinero and Fernando Brioso de la Rica of Garrigues examine the implications of a Spanish Supreme Court ruling on treaty relief when the Interest and Royalties Directive exemption is denied