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The Court of Appeal ruling clarifies that treaty benefits are not abusive where transactions are commercially driven, providing greater certainty on “main purpose” anti-avoidance tests
Despite the Netherlands featuring an unusual concentration of World Tax-ranked technology-led providers, sources believe there’s a long way to go to challenge the established players
Ethics seems to be playing a subservient role to an entitlement culture borne out of a pervasive ‘revenue at all costs’ mentality at the big four
Historical World Tax data suggests the ‘largest law firm merger in history’ may not pose a serious threat to the world's leading tax practices
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Sponsored by DeloitteChristine Ramsay and Takuma McNie of Deloitte explain how treating transfer pricing documentation as a risk management asset could help tax functions manage controversy, strengthen tax positions, and optimise costs -
Sponsored by DeloitteMultinational taxpayers are facing a growing compliance burden, say Vrajesh Dutia and Gregoire de Vogüé of Deloitte, as they highlight notable transfer pricing rulings concerning ranges, intragroup services, and loss-making entities
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Sponsored by DeloitteTax authorities are tightening their focus on intercompany loans, guarantees, and cash pooling. George Galumov and Immacolata Abbamondi of Deloitte explain how multinational enterprises can mitigate risks in financial transactions transfer pricing
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