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Direct Tax
The increasing sophistication of India’s taxation system has led to complexity across tax treaty benefits, permanent establishments, transfer pricing and more, say Sanjay Sanghvi and Ujjval Gangwal of Khaitan & Co
January 9, 2025
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Chinese tax authorities are increasing their scrutiny of high and new technology enterprises, which stresses the importance of strong documentation, says Abe Zhao of FenXun Partners -
Technology is on the way to relieve tax advisers tired by onerous pillar two preparations, says Russell Gammon of Tax Systems
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The BEPS project has seen the arm’s-length principle shift its focus to where human activity takes place, but Leonard Wagenaar questions if this is sustainable in a financialised world
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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 DeloitteEdward Morris of Deloitte UK and Sobhan Kar of Deloitte India question whether the adage that mutual agreement procedures work, but too slowly, is still correct.
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Sponsored by DeloitteFroukje Frerichs, Stefano Lavore, and Nicola Lostumbo of Deloitte provide a guide to the most common tax authority challenges in the business restructuring context and present a three-pronged approach to mitigating this risk.
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Sponsored by DeloitteGeoff Gill of Deloitte Australia and Andrew Skipsey of Deloitte UK analyse the use of profit split transfer pricing methods in the rapidly evolving banking and commodity trading businesses.
Local Insights
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Sponsored by MDDPRafał Kran and Łukasz Szatkowski of MDDP summarise a substantial revision of Poland’s real estate tax framework, with new definitions for buildings and structures, and a controversial change concerning construction equipment
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Sponsored by KPMG SwedenTobias Ljunggren and Jessica Silver of KPMG Sweden, who acted as counsel, analyse the implications of a court ruling clarifying that Audi’s winter testing in Sweden does not constitute a permanent establishment
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Sponsored by KPMG SwedenThomas Andersson and Tobias Almqvist of KPMG Sweden discuss a Supreme Administrative Court ruling affirming the right to judicial review of corresponding adjustments under tax treaties, ensuring legal remedies for double taxation disputes
