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

Bharathi Krishnaprasad of Lakshmikumaran & Sridharan analyses an Indian Supreme Court decision that expands the concept of permanent establishment and raises fresh questions about taxable presence without physical operations

Benjamin P Simatupang and Welly Armantha Napitupulu of GNV Consulting review Indonesia’s latest tax updates, including new income tax rules for e-commerce, changes to crypto asset taxation, gold bar levies, and revised import policies

Jun Au and Eddie Ahn of DLA Piper Australia examine the High Court’s 4-3 ruling in favour of PepsiCo, clarifying when royalty withholding tax and the diverted profits tax apply to distribution arrangements in Australia

João Sousa Magalhães of Morais Leitão, Galvão Teles, Soares da Silva & Associados considers the impact of the Portuguese tax authorities’ rulings on early redemptions and lump-sum payments from foreign pension plans

Paolo Ludovici, Andrea Iannaccone, and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici assess whether Italy’s reforms meet European Court of Human Rights standards on safeguards for inspections of homes and business premises

Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente examine how the new regime allows medium-sized taxpayers to access penalty relief and strengthen tax governance without joining the cooperative compliance scheme

Paulo Victor Vieira da Rocha and Marina Fernandes of VRMA Advogados analyse the Brazilian Federal Supreme Court’s review of the constitutional boundaries of the CIDE levy on international payments

Renata Colafêmina and Rafaela Calçada Cruz of Machado Associados examine full non-cumulative taxation under Brazil’s new IBS/CBS regime, the current consumption system’s credits restrictions, and the challenges of the new tax model

The protocol amending the Brazil–China double tax treaty is aimed at improving legal certainty, reducing withholding taxes, and preventing treaty abuse, say Paulo Victor Vieira da Rocha and Murilo Jakuk of VRMA Advogados

Henriette 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

Henriette 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”.

In 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.

Mark Martin and Thomas Bettge of KPMG in the US discuss the issue of implicit support and a recent IRS advice memorandum addressing transfer pricing for intercompany debt

Multinational companies face numerous year-end tasks but should not forget to file the treaty notifications that are required in certain US tax treaties, say senior tax practitioners from KPMG in the US

Mark Martin and Thomas Bettge of KPMG in the US analyse the 2022 mutual agreement procedure statistics for the US and discuss their significance for businesses

Niklas 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

Johannes 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

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