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Recent Indian case law emphasises the importance of economic substance over mere legal form in evaluating tax implications, say authors from Khaitan & Co
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
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Sponsored by DeloitteWith the pricing of intangibles laced with difficulty, Ishan Maini, Eric Linge, and Richard Schmidtke of Deloitte draw on two cases in Germany and Israel revolving around differing interpretations concerning the delineation of transactions -
Sponsored by DeloitteNicola Lostumbo and Jie Pan of Deloitte provide insights into high-value intercompany service charges, their role in creating value, and the most common tax authority challenges, before concluding with some considerations in mitigating risks
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Sponsored by KPMG SwedenÅsa Edesten and Mazlum Yildiz of KPMG Sweden say there remains a lack of clear legal precedent on the impact of ‘control over risk’ in assessing contractual terms between related parties, despite a recent ruling
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