Tax Disputes
Growing GAAR scrutiny is driving taxpayers to look beyond legal form and demonstrate the commercial rationale underpinning tax-efficient structures
Among the arrivals is Andrew Howell, who leaves scandal-hit PwC Australia after representing PepsiCo in a high-profile TP dispute
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2026 Europe Tax Awards
The Court of Appeal ruling clarifies that treaty benefits are not abusive where transactions are commercially driven, providing greater certainty on “main purpose” anti-avoidance tests
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Sponsored by CuatrecasasPedro Vidal Matos of Cuatrecasas reviews the EU Directive on Tax Dispute Resolution Mechanisms. Though far from perfect, it will enhance taxpayer protection and strengthen the EU’s double tax treaty network. -
Sponsored by Hager & PartnersGian Luca Nieddu and Barbara Scampuddu of Hager Partners analyse a Supreme Court ruling which declared a company was resident in the Netherlands because its effective management took place in this jurisdiction.
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Sponsored by BaseFirmaBrazil made a formal application to join the OECD in 2017, but the process is still mired with political uncertainty. BaseFirma's Davi Santana de Jesus outlies how the economy can expedite its application by reforming its transfer pricing framework.
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