LEAD ARTICLE
LEAD ARTICLE
Sponsored
Sponsored by
Svalner Atlas Advisors
Patrik Sedlar and William Berntö of Svalner Atlas Advisors draw on case law to question whether the Swedish Tax Agency’s stance on recharacterising intra‑group intangible property licensing arrangements conflicts with the OECD Transfer Pricing Guidelines
April 1, 2026
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Sponsored by Steadfast Business ConsultingMithilesh Reddy of Steadfast Business Consulting says multinationals must adopt proactive governance and robust compliance practices as the region’s transfer pricing environment develops at pace -
Sponsored by Saleh, Barsoum & Abdel Aziz – Grant Thornton EgyptRabie Morsy and Ahmed Khalifa of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt analyse the amendments and guidance, focusing on construction, commodities, exemptions, and practical compliance implications for businesses
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Sponsored by Saleh, Barsoum & Abdel Aziz – Grant Thornton EgyptRabie Morsy and Karim Adel of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt assess the package’s impact on dispute resolution, investment structures, and administrative efficiency
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Sponsored by Lakshmikumaran & SridharanSeveral key rulings clarify the taxation of cross-border payments as royalties with respect to ‘information concerning industrial, commercial or scientific experience’, say S Vasudevan, Prachi Bhardwaj, and Prakhar Pandey of Lakshmikumaran & Sridharan
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Sponsored by DLA Piper AustraliaKelvin Yuen and Suhani Mehra of DLA Piper Australia examine a Full Federal Court decision denying deductions for undocumented intragroup service fees, and the risks of relying on inferred contracts in related-party transactions
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Sponsored by HLB ThailandPaul Ashburn, Radapak Arthapridi, and Anna Selina De Vera of HLB Thailand explain how the update to the Commentary on Article 5 clarifies when employees’ homes may create a taxable permanent establishment in the country
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Sponsored by Svalner Atlas AdvisorsPatrik Sedlar and William Berntö of Svalner Atlas Advisors draw on case law to question whether the Swedish Tax Agency’s stance on recharacterising intra‑group intangible property licensing arrangements conflicts with the OECD Transfer Pricing Guidelines
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Sponsored by SumersonNicolas Duboille and Mathis Rossignol of Sumerson explain how France’s new withholding tax mechanism reshapes access to treaty relief and creates significant cash-flow and compliance implications
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Sponsored by Morais Leitão, Galvão Teles, Soares da Silva & AssociadosInês Dias Cardoso of Morais Leitão, Galvão Teles, Soares da Silva & Associados examines the measures and the potential next steps, with a VAT reduction on construction works at the forefront of developments
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Sponsored by MachadoStephanie Makin e Ana Lucia Marra, de Machado Associados, discutem as mudanças na incidência de IRRF em remessas ao exterior relativas à importação de serviços e seus impactos para grupos multinacionais.
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Sponsored by MachadoRicardo Marletti Debatin da Silveira and Rogério Gaspari Coelho of Machado Associados discuss a Supreme Court decision about the taxation of software licensing in Brazil.
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Sponsored by EY ColombiaAleksan Oundjian of EY looks at the tax framework for mergers in Colombia and explains why a more balanced and competitive tax environment is required.
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Sponsored by Vertex IncSal Visca of Vertex explains why tax professionals and authorities must evolve to keep pace with developments such as AI-executed transactions and real-time reporting
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Sponsored by Vertex IncChris Hall of Vertex explains how e-invoicing is becoming essential for multinational businesses, enabling compliance, operational efficiency, and friction-free participation in global trade amid increasingly digital tax regimes
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Sponsored by Morais Leitão, Galvão Teles, Soares da Silva & AssociadosBernardo Mesquita of Morais Leitão, Galvão Teles, Soares da Silva & Associados examines how AI can enhance tax administration efficiency while raising significant transparency, accountability, and taxpayer-rights concerns that governments must address
