Brazil’s bid to seek US-style exemptions from pillar two is ‘highly advantageous’ for multinationals, ITR has also heard
India is signalling flexibility on expat taxation to attract foreign expertise, though employers will need to navigate disclosure, treaty and scope uncertainties
Brazil is trying to follow in the US’s footsteps and secure its own 'qualified side-by-side status', ITR understands
The surge in probes comes as the UK tax authority seeks to close a VAT gap of £11.4bn from last year, Pinsent Masons’ research has suggested
Sponsored
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Sponsored by Tax PartnerStephanie Eichenberger and Victoria Riep of Tax Partner provide a guide to Switzerland’s securities transfer tax for domestic and foreign investors, explaining when it is triggered and how to mitigate unexpected tax consequences -
Sponsored by CuatrecasasAndré Areias and Raquel Santos Ferreira of Cuatrecasas scrutinise Portugal’s use of increased municipal property tax on vacant properties and question whether extreme rate multipliers and weak procedural safeguards can withstand constitutional scrutiny
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Sponsored by MFA Legal & TechSamuel Fernandes de Almeida and Ana Rita Carvalho of MFA Legal & Tech explain how a Portuguese binding ruling fuels the emerging dispute with Spain over non-habitual tax residents
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Multinational enterprises (MNEs) can choose to use tax risk insurance (TRI) to cover their VAT positions on new products that may fall outside the scope of existing legislation, such as new technologies or innovations.
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Tax directors say a new employee does not need to know every tax rule, but must show they are willing to learn, embrace new skills, be adaptable and, most importantly, offer something different.
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Tax directors in India say they are more optimistic about how they will handle tax and transfer pricing matters in the future because the government’s pro-business approach is having a positive impact.
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Courts around the world have adapted to working restrictions to combat COVID-19 and are managing to sustain immediate operations remotely, but it remains unclear what the long-term effect will be.
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Tax professionals in India warn that existing case law on tax treaty use will have almost no influence in a post-MLI world. The preamble to the Multilateral Instrument (MLI) will need to be tested in court.
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Cristina Caraccioli and Alessandro Valente of Crowe Valente/Valente Associati GEB Partners explain how amendments to a legal provision in the field of criminal law present an attractive opportunity for MNEs carrying out inter-company transactions.
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Following the surprise expansion of the scope of the equalisation levy to include all e-commerce transactions, Indian taxpayers say that it will be difficult to implement the levy because non-resident entities have to manage compliance.
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The Multilateral Instrument has fundamentally changed India’s permanent establishment (PE) rules with significant consequences for foreign multinational companies with preparatory and auxiliary services in the country.
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The UK revenue service, HMRC, will issue fresh guidance on its approach to permanent establishment (PE) rules since the COVID-19 lockdown has forced many non-resident businesses to rely on virtual meetings.
