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Direct Tax
The Court of Appeal ruling clarifies that treaty benefits are not abusive where transactions are commercially driven, providing greater certainty on “main purpose” anti-avoidance tests
July 7, 2026
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The repeal of Libya’s statute of limitations and tougher enforcement leave taxpayers navigating a high-stakes choice between conciliation and litigation -
A revised Chapter VII signals a move away from mechanical TP approaches, stressing transaction understanding, functional analysis and context-driven documentation requirements
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HMRC’s growing focus on evidencing tax decisions is shifting attention from technical accuracy to governance, requiring businesses to demonstrate how positions were reached and documented
Sponsored Features
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Sponsored by DeloitteSenior Deloitte tax practitioners explain how a hybrid e-invoicing model can enable multinationals to step off the compliance treadmill while balancing global consistency with local requirements
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Sponsored by DeloitteRonnie Dassen and Jan De Clercq of Deloitte Global outline how agentic AI can support indirect tax teams in managing compliance pressures, improving data quality, and freeing capacity for higher-value advisory work
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Sponsored by DeloitteSameer Nurmohamed, partner, Deloitte Legal Canada
Special Focus
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Sponsored by ATOZRomain Tiffon and Marie Bentley of ATOZ analyse how automation, data analytics, and generative AI are reshaping tax operations, enabling greater strategic insight while raising important challenges around data, governance, and implementation
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Sponsored by YulchonSeveral South Korean transfer pricing cases have established clearer judicial standards emphasising robust comparability analysis and stronger functional and economic evidence. Yulchon tax partners provide practical insights for navigating the heightened requirements
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Sponsored by RSM IndonesiaIchwan Sukardi and T Qivi Hady Daholi of RSM Indonesia examine how geopolitical conflict and economic volatility are reshaping transfer pricing risk and enforcement, with a particular focus on Southeast Asia and Indonesia
Local Insights
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Sponsored by Deloitte LuxembourgJean-Michel Henry and Mona El-Begawi of Deloitte Luxembourg examine the complexities created by timing differences in Luxembourg, EU, and OECD tax regimes
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Sponsored by MFA Legal & TechSamuel Fernandes de Almeida of MFA Legal & Tech assesses whether Portugal’s 7.5% surcharge on non-residents aligns with the EU’s free movement of capital principle and passes the proportionality test
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Sponsored by Deloitte LuxembourgIva Gyurova and Luca Derqui of Deloitte Luxembourg analyse landmark court decisions on intra-group financing, focusing on arm’s-length interest rates and their alignment with OECD transfer pricing guidance
