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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 DeloitteSimón Somohano and Francisco Díaz of Deloitte S-LATAM explain the changes for maquiladoras after the repeal of advance pricing agreements as a compliance option and the implications for Mexico’s competitiveness as a manufacturing location.
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Sponsored by DeloitteAriel Krinshpun and James Mahon, III of Deloitte US and George Galumov of Deloitte Switzerland analyse two areas of intercompany financing arrangements as transactions come under increasing scrutiny from tax authorities.
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Sponsored by DeloitteKirsti Longley of Deloitte Tax LLP and Carlos Serrano Palacio of Deloitte Spain explain the benefits of advance pricing agreements in managing transfer pricing exposure, and the pros and cons of unilateral and bilateral advance pricing agreements.
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
