Sponsored

Stephanie Eichenberger and Thomas Zellweger of Tax Partner explain how the choice of investment vehicle impacts the eligibility of non-Swiss investors for Swiss withholding tax refunds and, ultimately, investment performance

Sudin Sabnis and Siddhesh Khandalkar of Lakshmikumaran and Sridharan explore how context shapes the interpretation of undefined terms in tax treaties, balancing treaty text, domestic law, and diplomatic intent

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

João Riscado Rapoula and André Vilaça Ferreira of VdA outline the NHR 2.0 Portuguese tax incentive and explain why it could enhance the country’s appeal to expatriates and foreign businesses

Jun Au of DLA Piper Australia analyses a recent Full Federal Court decision on the Australian Taxation Office’s application of the general anti-avoidance rules, with the judgment also addressing dividend stripping and the taxation of financial arrangements

António Queiroz Martins and Carolina Braga Andrade of Morais Leitão, Galvão Teles, Soares da Silva & Associados explain the application of the rules in Portugal as the country helps lead global tax reform

Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente examine year-end transfer pricing adjustments in light of EU developments and implementation of the OIC 34 accounting standard in Italy

Fumiko Mizoguchi, partner, Tax & Legal, Deloitte Japan

Fernando Matesanz of Spanish VAT Services calls for a rethink of national VAT frameworks after two key judgments that support businesses correcting VAT when commercial transactions are altered, cancelled, or left unpaid