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Sponsored by Lakshmikumaran & SridharanKaranjot Singh Khurana, Loveena Manaktala, and Vrinda Agrawa of Lakshmikumaran & Sridharan suggest a legislative amendment may have created a recipe for litigation by non-resident investors regarding buy-back schemes until further clarity is provided
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Sponsored by TaxandSenior tax practitioners from five member firms of the Taxand network provide insights into enhanced tax audit scrutiny of transfer pricing in their jurisdictions and suggest several means of recourse for taxpayers
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Sponsored by Mascareño Vargas – AsesoresCarlos Jorge Vargas and Rodrigo Gómez Sánchez of Mascareño Vargas – Asesores explore Paraguay’s appeal to international investors and highlight the country’s competitive tax regime as a particularly significant factor in attracting foreign capital
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Sponsored by Kambourov & Partners Tax ConsultingDennitsa Dimitrova of Kambourov & Partners Tax Consulting highlights a significant tax risk in M&A transactions involving telecommunications operators and suggests what steps should be taken during the due diligence process
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Sponsored by DeloitteMariusz Każuch, Inka Traeger, and Conrad Marburg of Deloitte consider tax authorities' recharacterisation of intercompany transactions through drawing on recent practice in Poland and Germany, and suggest proactive measures global businesses can take
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Sponsored by DeloitteVrajesh Dutia and Michael Nixon of Deloitte explain the nuances of amount B as jurisdictions consider its adoption, and outline the uncertainties and challenges involved
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Sponsored by DeloitteAaron Wang, Carlo L Navarro, and Rebecca Cook of Deloitte explain several Asia-Pacific jurisdictions’ differing approaches towards the construction of an arm’s-length range amid the shifting contours of the region’s transfer pricing landscape
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Sponsored by DeloitteShaun Austin, Darcy Alamuddin, and Ryan McMahon of Deloitte analyse the feedback from the 2024 Deloitte transfer pricing controversy survey, highlighting key trends in the transfer pricing controversy space
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Sponsored by DeloitteCarlos Serrano Palacio, Richie Lombard, and Bernardo Misle of Deloitte analyse recent measures to resolve tax uncertainty in a climate of increasing transfer pricing audits and controversy, and consider what further steps should be taken