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LEAD ARTICLE

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Sponsored by Crowe Valente/Valente Associati GEB Partners
Federico 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
May 8, 2026
  • Sponsored by Deloitte Transfer Pricing Global
    An update to Russian transfer pricing regulations has seen an uptick in tax authority audits applying the comparable uncontrolled price (CUP) method. Deloitte’s Dmitry Kulakov, Alexey Sobchuk, Dmitriy Masharov, and Anastasia Kopysova explore the approach in three particular cases.
  • Sponsored by VdA
    Portuguese documentation requirements for tax exemption require EU pension funds to submit certifications that are difficult to obtain. Is this ultimately deterring pension funds from investing into Portugal?
  • Sponsored by Deloitte Switzerland
    Switzerland's Tax Reform and AHV Financing Bill (TRAF, formerly known as Swiss Tax Reform 17 and Swiss Corporate Tax Reform III) will officially be subject to a referendum, as a largely left wing alliance made up of junior green and socialist parties has secured more than 50,000 signatures against the proposed law. The public vote is now scheduled for May 19 2019.
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