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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
Tax auditors themselves had not been aware of the new TP ‘transaction matrix’ requirements, ITR hears as five German partners share their client experiences
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Sponsored by MDDPMarek Kończak and Tomasz Janik of MDDP say Poland’s draft amendment to the Corporate Income Tax Act addresses two key CJEU rulings but leaves open questions on scope, timing, and safeguards -
Sponsored by MachadoRenata Colafêmina and Rafaela Calçada Cruz of Machado Associados examine full non-cumulative taxation under Brazil’s new IBS/CBS regime, the current consumption system’s credits restrictions, and the challenges of the new tax model
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Sponsored by Deloitte LuxembourgEdouard Authamayou of Deloitte Luxembourg examines a tribunal ruling on hidden contributions and profit distributions that highlights the importance of robust evidence supporting the arm’s-length principle in intragroup financing arrangements and interest rate waivers
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