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Partners are divided on Italy vs PDM D’s analytical depth, evidentiary standards, and what the judgment signals for future intra-group financing cases
From tech preparations to competitiveness concerns, Tax Systems’ Russell Gammon addresses the most pressing client considerations arising from the SbS deal
The firm’s eye-catching UK launch is a major statement of intent, but it will face stern opposition in its quest to be the top global tax player
The postponement came after industry representatives flagged implementation issues with the registration regime; in other news, firms made key tax partner additions
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Sponsored by CreelMexico’s tax system lacks clarity on the status of cryptocurrencies. Treating them as either property or currency each have their own specific implications, writes Omar Zuñiga, partner, and Eduardo Brandt, senior associate, at Creel García-Cuéllar Aiza y Enríquez. -
Sponsored by KPMG Hong KongIn July 2018, transfer pricing (TP) legislation – Inland Revenue (Amendment) (No 6) Bill 2017 (BEPS Bill) – was passed in Hong Kong. This represents one of the biggest changes to Hong Kong tax in recent years. Many of the provisions within the BEPS Bill will have retrospective effect from the year of assessment 2018/19. The notable amendments to the initial proposal are:
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Sponsored by DLA Piper AustraliaOn June 21 2018, the Australian Taxation Office (ATO) released updated guidelines on the corporate residency test in Taxation Ruling TR 2018/5 and Draft Practical Compliance Guidelines PCG 2018/D3.
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