LEAD ARTICLE
LEAD ARTICLE
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Gatti Pavesi Bianchi Ludovici
Paolo Ludovici and Andrea Mirabella of Gatti Pavesi Bianchi Ludovici analyse the tax authorities’ ruling on cross-border dividend withholding and the domestic capital gains exemption as applied to a Maltese trust electing corporate tax status
November 6, 2025
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Sponsored by Deloitte Transfer Pricing GlobalStephen Weston, Silke Imig and Priscilla Ratilal interpret the potential impact of the OECD’s guidance for businesses in the financial services sector. -
Sponsored by Deloitte Transfer Pricing GlobalMatej Cresnik, Oliver Busch and Jeremy Brown explain how captive insurance companies of non-insurance groups have come under increased scrutiny from the judiciary and tax authorities.
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Sponsored by Deloitte Transfer Pricing GlobalStan Hales and Ralf Heussner consider the key challenges that the interbank offered rates (IBORs) reform faces from a transfer pricing (TP) perspective.
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Sponsored by Lakshmikumaran & SridharanS Vasudevan and Prachi Bhardwaj of Lakshmikumaran & Sridharan explain how India’s tax authorities face legal pushback over the Multilateral Instrument’s enforceability, with most favoured nation rulings now affecting its implementation
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Sponsored by GNV ConsultingJeklira Tampubolon and Dwipa Abimanyu Dewantara of GNV Consulting outline recent developments on import duties, the Directorate General of Taxes’ follow-up on concrete tax data, e-commerce taxation, and free trade zone regulations
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Sponsored by DLA Piper AustraliaJun Au and Eddie Ahn of DLA Piper Australia analyse the Australian Taxation Office’s framework for applying the third-party debt test and debt deduction creation rules under the country’s new thin capitalisation regime
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Sponsored by Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Andrea Mirabella of Gatti Pavesi Bianchi Ludovici analyse the tax authorities’ ruling on cross-border dividend withholding and the domestic capital gains exemption as applied to a Maltese trust electing corporate tax status
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Sponsored by MDDPJakub Warnieło and Aleksandra Bulaszewska of MDDP outline the key takeaways from a report on Polish tax trends, covering tax inspections, verification activities, tax proceedings, and the business viewpoint
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Sponsored by EY RomaniaCorina Mîndoiu and Geanina Ciorâță of EY Romania explain how the country’s flat-tax consistency, digital integration, and transparent residency rules continue to attract investors, professionals, and digital nomads from around the world
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Sponsored by MachadoGabriel Caldiron Rezende of Machado Associados comments on the rising concerns about the tax reform transition phase, especially concerning how the old taxes will be calculated during their coexistence with the new system
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Sponsored by MachadoGabriel Caldiron Rezende of Machado Associados comments on the prominent role to be played by digital platforms under the new Brazilian VAT regime and the relevant compliance reporting framework
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Sponsored by MachadoRenata Colafêmina and Rafaela Calçada da Cruz of Machado Associados discuss the test rates and ancillary obligations to be implemented from 2026, as Brazil prepares for its sweeping consumption tax changes
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Sponsored by Deloitte LuxembourgDinko Dinev of Deloitte Luxembourg explores how automation is transforming debt pricing studies in transfer pricing, highlighting efficiency gains but also analytical risks that can arise if technology is misapplied
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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
