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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
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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
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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
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Sponsored by CuatrecasasLiliana Piedade and João Filipe Rodrigues of Cuatrecasas argue for a substantive interpretation of Portugal’s stamp duty exemption on guarantees provided by financial institutions, credit institutions, and similar entities to counterparts of an identical nature
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Sponsored by AKM GlobalAmit Maheshwari and Manish Garg of AKM Global provide a guide to the UAE’s nascent regulatory framework for transfer pricing and offer strategies to ensure compliance and the maintenance of proper documentation
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Sponsored by DeloitteD’Arcy Schieman, partner, indirect tax, Deloitte Canada
Special Focus
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Sponsored by DeloitteShaun Austin, Darcy Alamuddin, and Ryan McMahon of Deloitte analyse the feedback from the 2024 Deloitte transfer pricing controversy survey, highlighting key trends in the transfer pricing controversy space
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Sponsored by Kambourov & Partners Tax ConsultingDennitsa Dimitrova of Kambourov & Partners Tax Consulting highlights a significant tax risk in M&A transactions involving telecommunications operators and suggests what steps should be taken during the due diligence process
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Sponsored by DeloitteVrajesh Dutia and Michael Nixon of Deloitte explain the nuances of amount B as jurisdictions consider its adoption, and outline the uncertainties and challenges involved
Local Insights
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Sponsored by CuatrecasasSerena Cabrita Neto of Cuatrecasas explains how the Administrative Arbitration Centre’s ability to make preliminary references to the Court of Justice of the European Union has helped assimilate EU tax jurisprudence in Portugal
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Sponsored by Vertex IncFernando Silva of Vertex provides a guide to the ambitious transformation of Brazil’s complicated tax landscape, and says careful navigation will be required to negotiate dual VAT and phased implementation
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Sponsored by Lakshmikumaran & SridharanRaghavan Ramabadran, Krithika Jaganathan, and Nirupama Shankar of Lakshmikumaran & Sridharan explore the tax benefits available to businesses under India’s special economic zones framework and the practicalities and challenges of the SEZ Online system