LEAD ARTICLE
LEAD ARTICLE
Sponsored
Sponsored by
Gatti Pavesi Bianchi Ludovici
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Sponsored by Saleh, Barsoum & Abdel Aziz – Grant Thornton EgyptWhile the rule could result in enhanced tax revenues, Egypt must consider its effect on foreign direct investment, say Rabie Morsy, Karim Adel, and Sandra Aziz of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt
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Sponsored by VdAJoão Riscado Rapoula and Luís Maria of Vieira de Almeida & Associados conduct an in-depth analysis of the Portuguese and Angolan general anti-abuse rules, with a particular focus on the similarities and differences
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Sponsored by Saleh, Barsoum & Abdel Aziz – Grant Thornton EgyptWith transfer pricing principles becoming increasingly important as start-ups expand, Nouran Ibrahim and Maureen Guirguis of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt explain the salient points and how to meet the challenges
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Sponsored by DLA Piper AustraliaSarah Gard of DLA Piper Australia summarises the Australian Taxation Office’s draft guidance on determining whether the amount of inbound, cross-border related party debt is consistent with the arm’s-length conditions for transfer pricing purposes
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Sponsored by HLB ThailandAndrew Jackomos and Amit Bhalla of HLB Thailand examine how evolving global tax standards are reshaping the treatment of intragroup royalty payments and driving stricter compliance and documentation requirements
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Sponsored by DLA Piper AustraliaJun Au of DLA Piper Australia analyses a recent Full Federal Court decision on the Australian Taxation Office’s application of the general anti-avoidance rules, with the judgment also addressing dividend stripping and the taxation of financial arrangements
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Sponsored by Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Andrea Iannaccone of Gatti Pavesi Bianchi Ludovici analyse an Italian Supreme Court decision that addresses the tax treaty concept of a fixed base, highlighting concerns over legal certainty and double taxation
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Sponsored by Garrigues SpainRafael Calvo and Adrián Arroyo of Garrigues Madrid discuss a National Court judgment clarifying that interest on equity (JSCP) received from Brazilian entities qualifies for an exemption under the Spain–Brazil double tax treaty
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Sponsored by Alma LEDMarco Sandoli and Lorenzo Marantonio of Alma LED challenge the Revenue Agency’s ‘unsupportable’ interpretation on tax exemptions for business and shareholding transfers through trusts when taxation is applied at the time of asset segregation
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Sponsored by VRMA AdvogadosPaulo Victor Vieira da Rocha and Murilo Jakuk of VRMA Advogados analyse the application of Brazil’s federal tax on industrialised products to intragroup goods transfers, after a ruling that addressed alleged tax planning abuses
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Sponsored by MachadoGabriel Caldiron Rezende and Juliana Mari Tanaka of Machado Associados discuss the impact of Brazil’s consumption tax reform on financial services, with a particular focus on the taxation of banking spreads
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Sponsored by MachadoGabriel Caldiron Rezende and Rafaela Calçada Cruz of Machado Associados discuss the impacts of the consumption tax reform on agribusiness, focusing on sector-specific concessions, challenges, and strategic responses
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Sponsored by Yaron-Eldar Paller Schwartz & CoHenriette Fuchs of Yaron-Eldar, Paller, Schwartz & Co in Tel Aviv reports on two substantial new tax benefits designed to stimulate and preserve continued investment in technology companies
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Sponsored by Yaron-Eldar Paller Schwartz & CoHenriette Fuchs of Yaron-Eldar, Paller, Schwartz & Co in Tel Aviv concludes the follow-up article on SAFE investments in Israel, outlining the relative certainty of walking the safe “green path”.
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Sponsored by Yaron-Eldar Paller Schwartz & CoIn the first of a two-part article, Henriette Fuchs of Yaron-Eldar, Paller, Schwartz & Co in Tel Aviv reports on Israel tax authorities’ acceptance of the SAFE for investment in innovative and tech companies.
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Sponsored by Vertex IncMichael Bernard of Vertex says adapting to the US’s challenging tax regime relies on an understanding of what is known as the nexus principle
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Sponsored by Vertex IncWith 45 states imposing a sales tax, Michael Bernard of Vertex explains the key points to note for European businesses aiming to broaden their market and capitalise on the e-commerce boom in the US
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Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US discuss the recent amount B consensus document and the associated compliance challenges
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Sponsored by KPMG SwedenNiklas Elofsson and Vsevolod Konyshev of KPMG Sweden explore how tax functions can unlock demonstrable efficiency gains by using generative AI tools in a budget-constrained transformation landscape
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Sponsored by KPMG SwedenJohannes Bangum, Maria Barenfeld, and Peter Nilsson of KPMG Sweden explain the main pillar two issues that arise in corporate acquisitions, including scope acceleration, top-up tax responsibilities, and earnout treatment
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Sponsored by Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici discuss the latest developments in the OECD International Compliance Assurance Programme and evaluate its role within the framework of tax certainty