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Peru’s approach to TP is increasingly at odds with OECD-style profitability policies, exposing multinational groups to asymmetric tax adjustments
The DS Advocates partner discusses career reinvention, tax disputes and why advisory and litigation experience should complement one another
Lindsay Clayton’s arrival at Baker McKenzie continues the firm’s storied pursuit of ex-US government lawyers, a strategy reinforced by robust World Tax rankings
As pillar two reshapes global tax competition, the UK faces a crucial challenge: how to remain attractive to multinationals without sacrificing tax revenues
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Sponsored by MDDPMarek Kończak and Tomasz Janik of MDDP examine signs of a more pragmatic interpretation of Poland’s corporate income tax exemption for foreign investment funds, particularly where investment strategies include real estate
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Sponsored by Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Andrea Mirabella of Gatti Pavesi Bianchi Ludovici analyse a recent Italian Supreme Court decision that confirms the application of the three-test beneficial ownership framework to treaty-protected royalty payments
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Sponsored by MFA Legal & TechBárbara Miragaia of MFA Legal & Tech argues that the regime’s restrictive eligibility rules and limited relief for intra-group transactions may constrain its practical benefits
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