Firm
MNEs now face a shift from modelling to execution as the side‑by‑side deal forces tax teams to upgrade systems, harmonise data, and prevent costly pillar two mismatches
As recent surveys suggest a disconnect between AI adoption and employee engagement, the big four risk digging themselves into a strategic hole
Almost three-quarters of surveyed tax professionals are concerned about inaccurate AI outputs; in other news, Dentons hired a partner from CMS to lead its Belgian tax team
Long-running, high-value and complex enquiries are a significant reason for HM Revenue and Customs’s increased TP yield, experts suggest
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Sponsored by Gatti Pavesi Bianchi LudoviciGloBE reporting obligations following the side-by-side package’s introduction: an evolving frameworkPaolo Ludovici and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici consider what to expect with regard to global minimum tax reporting obligations following the implementation of the side-by-side package -
Sponsored by DLA Piper AustraliaKelvin Yuen and Suhani Mehra of DLA Piper Australia examine a Full Federal Court decision denying deductions for undocumented intragroup service fees, and the risks of relying on inferred contracts in related-party transactions
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Sponsored by HLB ThailandPaul Ashburn, Radapak Arthapridi, and Anna Selina De Vera of HLB Thailand explain how the update to the Commentary on Article 5 clarifies when employees’ homes may create a taxable permanent establishment in the country
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