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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
Tax auditors themselves had not been aware of the new TP ‘transaction matrix’ requirements, ITR hears as five German partners share their client experiences
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Sponsored by Spanish VAT ServicesFernando Matesanz of Spanish VAT Services welcomes a clear decision on how to categorise vouchers as the VAT treatment of such promotional schemes becomes ever more complex -
Sponsored by Lakshmikumaran & SridharanPrachi Bhardwaj and S Vasudevan of Lakshmikumaran & Sridharan explain how tax treaty provisions concerning the allowability of deductions for Indian residents align with non-discrimination clauses
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Sponsored by Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Luca Tortorella of Gatti Pavesi Bianchi Ludovici highlight two recent Italian tax court decisions regarding admissibility to mutual agreement procedures where the double taxation derives from self-adjustments rather than formal assessments
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