Feature
A revised Chapter VII signals a move away from mechanical TP approaches, stressing transaction understanding, functional analysis and context-driven documentation requirements
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
In the second instalment of this two-part series, Jayne Stokes takes a practical approach to navigating the capital v revenue question for UK R&D claims for software development, and shares pointers for businesses
Arindam Mitra and Robin Hart examine how aggregate TP rules clash with transaction-level customs rules, creating compliance risks and requiring granular, SKU-level pricing strategies
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Sponsored by DeloitteJohan Van der Paal and Bram Fouache of Deloitte Belgium explain how the EU’s VAT in the Digital Age Directive is reshaping VAT compliance across Europe, and how businesses can prepare for digital reporting and e-invoicing reforms -
Sponsored by Lakshmikumaran & SridharanSudin Sabnis and Siddhesh Khandalkar of Lakshmikumaran and Sridharan explore how context shapes the interpretation of undefined terms in tax treaties, balancing treaty text, domestic law, and diplomatic intent
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Sponsored by DeloitteFumiko Mizoguchi, partner, Tax & Legal, Deloitte Japan
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