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The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, and rejects protection for indirect transfers and tightening conditions for Mauritius‑based investors claiming DTAA relief
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems
Partners want to join Ryan because it’s a disruptor firm, truly global and less bureaucratic, Tom Shave told ITR
The Netherlands-based bank was described as an ‘exemplar of total transparency’; in other news, Kirkland & Ellis made a senior tax hire in Dallas
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Sponsored by CuatrecasasAndré Areias and Liliana Piedade of Cuatrecasas report on a preliminary ruling request by the Portuguese Arbitral Court and consider the decision’s expected impact on taxpayers
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Sponsored by Galicia AbogadosAn uptick in nearshoring activities in Mexico has led to heightened interest in trusts that specialise in energy and infrastructure investments. Federico Scheffler, Eduardo Espinosa, and Ileana García of Galicia Abogados explain the nuances
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Sponsored by DeloitteRalf Heussner, Anodri Suchdeve, and Fangying Xu of Deloitte examine the transfer pricing challenges arising from an increasing number of intra-bank funding arrangements as stricter capital requirements trigger the attention of regulators and tax authorities
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