Firm
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
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 Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente examine a recent ruling revisiting how control is defined in the context of transfer pricing regulations -
Sponsored by Spanish VAT ServicesFernando Matesanz of Spanish VAT Services examines a judgment confirming that denying input VAT and imposing joint liability may be applied together to combat fraud, provided the principle of proportionality is respected
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Sponsored by VRMA AdvogadosThe protocol amending the Brazil–China double tax treaty is aimed at improving legal certainty, reducing withholding taxes, and preventing treaty abuse, say Paulo Victor Vieira da Rocha and Murilo Jakuk of VRMA Advogados
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