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Direct Tax
Geopolitical rivalry is reshaping global tax cooperation, as the OECD’s minimum tax framework fragments and the EU grapples with the ensuing legal fallout
April 6, 2026
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 -
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 Spanish VAT ServicesFernando Matesanz of Spanish VAT Services reports on a domestic ruling that draws on CJEU case law concerning the tax treatment of professional services provided by a company's board members
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Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente provide a guide to Italy’s transitional country-by-country reporting safe harbours for groups within the scope of the pillar two global minimum tax requirements
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Sponsored by HLB ThailandPaul Ashburn, Amit Bhalla, and Urika Solano of HLB Thailand provide an update on Thailand’s progress towards implementation of BEPS 2.0 and explain why governmental agencies and multinational enterprises should undertake comprehensive reassessments
