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Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente examine how the Italian tax authorities scrutinise financial transactions and cash pooling arrangements, with potential recharacterisation risks under transfer pricing rules

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

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

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