Expert Analysis

The UK Upper Tribunal’s pragmatic approach to anti-abuse provisions will be welcomed by the secondary debt market, say Matthew Greene and Guy Bud of Stewarts

Recent UK case law shows the courts are ready to use a realistic approach to withholding tax exemption issues, writes Michael Alliston, partner at Norton Rose Fulbright

HMRC’s attempts to crack down on fraudulent tax relief claims are well-meaning, but the agency risks penalising genuinely innovative businesses, writes Katy Long of ForrestBrown

Join ITR and Thomson Reuters on July 16 as a three-part webinar series concludes with real-world insights into how businesses are managing the e-invoicing transition and the strategies enabling global compliance

Johan Van der Paal and Bram Fouache of Deloitte Belgium explain how the EU’s VAT in the Digital Age Directive is reshaping VAT compliance across Europe, and how businesses can prepare for digital reporting and e-invoicing reforms

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

Vanesa Lanciotti of Deloitte Chile explores how recent reforms – including new advance pricing agreement rules, enhanced audit priorities, and disclosure requirements – are reshaping transfer pricing practice and compliance for multinationals operating in Chile

Senior Deloitte tax practitioners examine Mexico’s evolving approach to the OECD’s amount B and summarise the transfer pricing landscape in Guatemala, Panama, Honduras, and Costa Rica

Senior Deloitte tax practitioners report that transfer pricing audits are homing in on intercompany services in Argentina, Uruguay, Colombia, Peru, Ecuador, and Venezuela, and emphasise the need for early taxpayer preparation

Paulo Victor Vieira da Rocha and Murilo Jakuk of VRMA Advogados analyse the application of Brazil’s federal tax on industrialised products to intragroup goods transfers, after a ruling that addressed alleged tax planning abuses

Ricardo Seabra Moura of Morais Leitão, Galvão Teles, Soares da Silva & Associados analyses how Portugal’s withholding tax rules on interest payments may unlawfully discriminate against companies based in European Economic Area countries

Łukasz Kosonowski and Szymon Konieczny of MDDP examine how Poland’s Estonian-style corporate income tax regime is offering increasing benefits to domestic and foreign investors seeking deferral and lower dividend withholding tax