The arrival of a team from Brazilian rival Costa Tavares Paes Advogados brings SiqueiraCastro’s tax headcount to seven partners and 30 associates
CSR initiatives can sometimes venture into virtue signalling, but Ryan’s tax literacy event for schoolchildren was a genuine and necessary endeavour
Grant Thornton advanced plans to integrate its Australian firm into its US arm, as tax developments spanned law firm hires, aviation levies and digital services taxes
A new focus on early intervention and increased AI use is transforming how tax authorities are approaching TP audits, though capacity-constrained jurisdictions risk falling behind
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Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe examine a recent decision concerning the transfer pricing treatment of non-remunerated intra-group guarantees, focusing on economic substance, legal form, and group-level business justifications -
Sponsored by McCarthy TétraultThe key changes under Budget 2025 and the outlook for 2026 raise several areas of heightened focus for taxpayers, say Matthew Kraemer, Adam N Unick, and Justin Ng of McCarthy Tétrault
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Sponsored by Lakshmikumaran & SridharanThe Tiger Global Supreme Court ruling weakens the status of tax residency certificates under tax treaties and increases substance‑based scrutiny, say S Vasudevan, Bharathi Krishnaprasad, and Krishna Laasya V of Lakshmikumaran & Sridharan
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The Court of Justice of the European Union (CJEU) issued a decision on October 4 2017 that clarifies the VAT treatment of certain automobile leasing agreements.
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The Maltese notional interest deduction rules (the rules) were published on October 5 2017, further to an announcement made in the previous 2017 budget. Traditionally, debt financing in Malta has been regarded as more efficient from a tax perspective due to the deductibility against chargeable income of finance costs incurred by companies upon the granting of loans. The main objective of the rules is to approximate the manner in which cost of equity and cost of debt are treated from a tax perspective. The rules provide certain undertakings with the possibility of deducting interest they are deemed to have incurred on equity.
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The German tax legislator made only a few substantial changes to the tax rules relevant for international business during 2017, the notable exception being the introduction of a new rule that will limit the deductibility of royalty payments made to recipients benefiting from a non-nexus intellectual property (IP) regime, which will apply from 2018 (see March issue of the International Tax Review magazine). In addition, the German courts issued some decisions that will require the legislator to introduce new rules, such as the replacement of the restructuring relief previously granted under an administrative practice based on a circular (see April issue of the International Tax Review magazine) and new change-in-ownership rules (discussed below). Most other changes to the tax code addressed procedural issues, such as increased notification requirements for certain business relationships with third countries and certain reliefs, by increasing the thresholds that allow simplified approaches to depreciation/amortisation, documentation, etc.
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The Brazilian National Congress approved a protocol on October 5 2017 that amends the double tax agreement (DTA) between Brazil and Norway in order to improve the exchange of information between the competent authorities of both contracting states.
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According to the law on clean air, adopted by the Iranian Parliament on July 16 2017, Mohammad Masihi, an official from the tax administration, stated that all home-grown, eco-friendly, zero-emission hybrid and electric cars and motorcycles will benefit from a tax exemption.
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The Australian Treasurer Scott Morrison released exposure draft legislation on November 24 to prevent entities that are liable to Australian income tax from avoiding income taxation or obtaining a double non-taxation benefit by utilising differences between the tax treatment of entities and instruments across different countries.
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The European Parliament Committee of Inquiry into Money Laundering, Tax Avoidance and Tax Evasion (PANA) is a new entry this year The PANA Committee was set up in June 2016, after the Panama Papers – a leak of 11.5 million files from offshore law firm Mossack Fonseca that shed light on the tax affairs of government officials, celebrities and business people. The committee has conducted a comprehensive investigation into tax avoidance, tax evasion and money laundering, and has influenced the debate on everything from protection of whistleblowers to EU tax law. Although the investigation is finished and the committee dissolved on December 8, its findings will have an impact on tax policy debate for years to come.
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Pierre Moscovici was also in the Global Tax 50 2015 and 2014 As one of the most important agenda-setters for EU tax policy, European Commissioner Pierre Moscovici has made it into this year's Global Tax 50 after one year of absence. Moscovici oversees tax policy in his role on the European Commission. He speaks to International Tax Review about the achievements of the past year and what lies ahead in 2018.
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Alexandra Readhead is a new entry this year Alexandra Readhead's work focuses on issues of tax avoidance and other forms of illicit financial flows by multinational extractive companies in developing countries. Readhead has directly assisted governments in Sierra Leone, Guinea, Ghana, Tanzania, Zambia, and Cote d'Ivoire on strengthening legal frameworks against abusive transfer pricing in the mining sector. She is technical adviser to the Intergovernmental Forum on Mining, Metals and Sustainable Development (IGF) on its programme 'Tax Base Erosion and Profit Shifting in the Mining Sector in Developing Countries'.
