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

Karanjot Singh Khurana, Prachi Bharadwaj, and Vrinda Agrawal of Lakshmikumaran & Sridharan analyse the tax deduction challenges arising when employee stock option plans are implemented via trusts

Sarah Gard of DLA Piper Australia summarises the Australian Taxation Office’s draft guidance on determining whether the amount of inbound, cross-border related party debt is consistent with the arm’s-length conditions for transfer pricing purposes

Andrew Jackomos and Amit Bhalla of HLB Thailand examine how evolving global tax standards are reshaping the treatment of intragroup royalty payments and driving stricter compliance and documentation requirements

Paolo Ludovici and Andrea Iannaccone of Gatti Pavesi Bianchi Ludovici analyse an Italian Supreme Court decision that addresses the tax treaty concept of a fixed base, highlighting concerns over legal certainty and double taxation

Rafael Calvo and Adrián Arroyo of Garrigues Madrid discuss a National Court judgment clarifying that interest on equity (JSCP) received from Brazilian entities qualifies for an exemption under the Spain–Brazil double tax treaty

Marco Sandoli and Lorenzo Marantonio of Alma LED challenge the Revenue Agency’s ‘unsupportable’ interpretation on tax exemptions for business and shareholding transfers through trusts when taxation is applied at the time of asset segregation

Paulo Victor Vieira da Rocha and Murilo Jakuk of VRMA Advogados analyse the application of Brazil’s federal tax on industrialised products to intragroup goods transfers, after a ruling that addressed alleged tax planning abuses

Gabriel Caldiron Rezende and Juliana Mari Tanaka of Machado Associados discuss the impact of Brazil’s consumption tax reform on financial services, with a particular focus on the taxation of banking spreads

Gabriel Caldiron Rezende and Rafaela Calçada Cruz of Machado Associados discuss the impacts of the consumption tax reform on agribusiness, focusing on sector-specific concessions, challenges, and strategic responses

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.

The Ninth Circuit reversed, and then withdrew its reversal of, the Tax Court's unanimous 'reviewed by the court' decision in Altera Corp. v. Commissioner, 145 T.C. 91 (2015), and held in a 2-1 decision that Treas. Reg. § 1.482-7(d)(2), requiring related entities to share the cost of employee stock compensation (the 2003 Regulation) was a valid regulation.

During 2017 and 2018, Mexico’s President Enrique Peña Nieto issued diverse decrees designating the following Mexican regions (shown in the map below) as special economic zones (SEZs).

Mexico’s tax system lacks clarity on the status of cryptocurrencies. Treating them as either property or currency each have their own specific implications, writes Omar Zuñiga, partner, and Eduardo Brandt, senior associate, at Creel García-Cuéllar Aiza y Enríquez.

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