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Recent Indian case law emphasises the importance of economic substance over mere legal form in evaluating tax implications, say authors from Khaitan & Co
PepsiCo was represented by PwC, while the ATO was advised by MinterEllison, an Australian-headquartered law firm
As we move into an era of ‘substance over form’, determining the fundamental nature of a particular instrument is key when evaluating the tax implications of selling hybrid securities
The US president has raised India’s tariff rate to 50% because of its importation of Russian oil; in other news, firms made key international tax partner hires
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Sponsored by CuatrecasasAna Helena Farinha and Tiago Martins de Oliveira of Cuatrecasas say that the intragroup financing of Portuguese companies could be affected by a rule that is out of kilter with several other EU jurisdictions -
Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US discuss the tax certainty provisions of the Multilateral Convention for amount A and evaluate their utility for businesses
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Sponsored by Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Andrea Iannaccone of Gatti Pavesi Bianchi Ludovici argue that a decision by the Italian court violates the European freedoms in treating a non-resident taxpayer differently from resident entities without justification
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