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 Mattos FilhoBrazil's highest court has challenged the attorney's office, shutting down an attempt to restrict taxpayers from accessing social security tax credits -
Sponsored by Deloitte MexicoMexico's First Circuit Court has recently ruled against a taxpayer in a case involving two transfer pricing adjustments that will make it tougher for companies to comply with their domestic tax obligations on time.
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Sponsored by Mattos FilhoTaxpayers are still waiting for clarity in one of Brazil’s most important tax disputes, which cost the federal government around BRL 250 billion ($68 billion) when it was concluded in March 2017.
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