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Sucafina’s tax chief was speaking at the ITR Pillar 2 Forum in London alongside experts from HMRC and other organisations
India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
The UK-based big four spin-off firm has hired Marc Lien, who declared that most AI in professional services today is ‘cosmetic’
Projected revenue losses and exemption requests are harming the project’s capability and viability

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  • The US Tax Court will have to once again review whether Medtronic’s use of the comparable uncontrolled transactions (CUT) method complied with regulations after the Eighth Circuit Court referred the case back for deeper analysis.
  • Georgios I. Katrinakis
  • Teodosia Kirilova
  • Chris Damianou
  • Eija Kuivisto
  • Petr Toman
  • Bernhard Groehs
  • At the regional level, there is a strong concern regarding the European Commission activity, following the Base Erosion and Profit Shifting works and recommendations. So EU governments and tax administrations are looking carefully at the same options, even if, of course, the intensity varies from one Member State to another. Looking at some countries, and more specifically at France, there is an increased, ongoing pressure from tax authorities regarding things like tax raids.
  • Peter Bjare
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