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 MachadoA decision rendered by the Superior Court of Justice in favour of the taxpayers determines the concept of inputs for calculating and booking PIS and Cofins credits. -
Sponsored by Deloitte MexicoA recent court ruling in Mexico has enabled the tax authorities to dive deeper into taxpayer affairs to determine whether transactions have real substance. Carlos Ramírez & Víctor Masón of Deloitte Mexico explain why taxpayers should take note of this judgment.
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Sponsored by Deloitte MexicoThe SAT ruling now has expanded the situations where the 4.9% withholding tax rate is not applicable to include interest derived from certificates, loans and other financial transactions.
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