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Saffery cautioned that documentation requirements in new government proposals must be limited if medium-sized companies are not exempted from TP
Section 899 of the ‘one big beautiful’ bill would have spelled disaster for many international investors into the US, but following its shelving, attention turns to the fate of the OECD’s pillars
Tax expert Craig Hillier agrees with the comparison of pillar two to using a sledgehammer to crack a nut
The US president also unveiled a new 50% levy on copper imports; in other news, a UK wealth tax proposal has been criticised by the Institute for Fiscal Studies
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Sponsored by Lakshmikumaran & SridharanKaranjot Singh Khurana, Prachi Bharadwaj, and Vrinda Agrawal of Lakshmikumaran & Sridharan analyse the tax deduction challenges arising when employee stock option plans are implemented via trusts -
Sponsored by Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Andrea Iannaccone of Gatti Pavesi Bianchi Ludovici analyse an Italian Supreme Court decision that addresses the tax treaty concept of a fixed base, highlighting concerns over legal certainty and double taxation
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Sponsored by Garrigues SpainRafael Calvo and Adrián Arroyo of Garrigues Madrid discuss a National Court judgment clarifying that interest on equity (JSCP) received from Brazilian entities qualifies for an exemption under the Spain–Brazil double tax treaty
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