Nouran Ibrahim and Mahmoud Ashraf of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt say taxpayers required to submit transfer pricing documentation could avoid penalties by acting in response to a recently published law

Rabie Morsy and Karim Adel of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt summarise three laws designed to facilitate the growth of SMEs and business as a whole through simplified tax procedures and incentives

Nouran Ibrahim and Karim Adel of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt say mutual agreement procedures will have a vital role to play as the country modernises its tax infrastructure

Hartiadi Budi Santoso and Arip Prastyo Wibowo of GNV Consulting Services summarise the application of the waiver, along with new regulations regarding customs audit and excise audit procedures, and free trade zone customs declarations

Kelvin Yuen of DLA Piper Australia summarises proposed changes to the managed investment trust regime, the deferral of a mooted foreign resident capital gains tax measure, and increased funding for the Australian Taxation Office

S Sriram and Dinesh Kukreja of Lakshmikumaran and Sridharan examine the tax consequences of foreign business reorganisations in India, including indirect transfer rules, statutory exemptions, and treaty benefits for multinational companies

Paolo Ludovici and Andrea Mirabella of Gatti Pavesi Bianchi Ludovici comment on a judgment regarding the withholding tax exemption for outbound interest on financing received indirectly by foreign investment funds as beneficial owners

Francesco Di Bari of Alma LED explains how an Italian Supreme Court ruling marks a pivotal shift in the tax treatment of interest on indirect lending, restoring key exemptions for qualified foreign institutional investors

Edouard Authamayou and Christelle Larcher of Deloitte Luxembourg explain how several recent rulings have clarified the Administrative Court’s stance on the application of ex officio taxation in the grand duchy

Sandra Benedetto and Jonatan Israel of PwC Chile provide an overview of a law establishing a new legal concept that aligns taxation with ESG principles, and consider its implications for Chilean companies

Gabriel Caldiron Rezende of Machado Associados summarises the general aspects of the recently enacted Brazilian tax reform and calls on businesses to conduct a thorough assessment of its potential impact

Loreto Pelegrí Haro and Rodrigo Winter Salgado of PwC Chile outline the main changes but note that the finalisation of an Internal Revenue Service circular letter will be crucial in clarifying the law’s application

Juan Ignacio de Molina and Christine Ramsay of Deloitte consider the increased reliance of tax authorities on CbCR data and how the data reported in the CbCR during the COVID-19 pandemic could impede its use.

Edward Morris and Jamie Hawes of Deloitte discuss how the resolution of controversy has changed with the introduction of a more efficient system to handle MAPs and APAs.

Shaun Austin, Richard Schmidtke and Aparna Rao of Deloitte discuss the challenging transfer pricing concepts of intangibles arrangements and important regulatory changes from Australia and Germany.

Michael Bernard of Vertex says adapting to the US’s challenging tax regime relies on an understanding of what is known as the nexus principle

With 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

Mark Martin and Thomas Bettge of KPMG in the US discuss the recent amount B consensus document and the associated compliance challenges

Paolo 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

Dinko Dinev and Adam Wojewoda of Deloitte Luxembourg explore AI’s potential to enhance efficiency in transfer pricing but emphasise the irreplaceable value of human expertise in navigating complex regulatory landscapes

Multinational enterprises must include transfer pricing and cost accounting experts in taking an integrated approach to supporting the arm’s-length nature of intragroup service charges, say Enrique Marchesi-Herce, Gilles Andreini, and Serena Picariello of Deloitte Luxembourg