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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 DDTC ConsultingTami Putri Pungkasan and Yurike Yuki of DDTC Consulting say an Indonesian transfer pricing update recognises the prevention of double taxation as a purpose and not merely as a means to prevent tax avoidance
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Sponsored by Skeppsbron SkattIngrid Faxing and Henri Ahtiainen of Skeppsbron Skatt analyse a proposal to incorporate the OECD Transfer Pricing Guidelines into EU law and question whether it will become a reality after several objections
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Sponsored by Gatti Pavesi Bianchi LudoviciThe Italian Supreme Court has ruled that a natural person does not need to be actually subject to individual income tax to receive tax treaty protection, report Paolo Ludovici and Ludovica Lorenzetto of Gatti Pavesi Bianchi Ludovici
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