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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
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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
Sponsored Features
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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 DeloitteCarlos Serrano Palacio, Richie Lombard, and Bernardo Misle of Deloitte analyse recent measures to resolve tax uncertainty in a climate of increasing transfer pricing audits and controversy, and consider what further steps should be taken
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Sponsored by DeloitteThe complex distinction between legal ownership and economic ownership of intangible assets means multinationals must take proactive measures to avoid transfer pricing controversy, say Christine Ramsay, Jordi Morera, and Marguerite Mei of Deloitte
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Sponsored by DeloitteWith the pricing of intangibles laced with difficulty, Ishan Maini, Eric Linge, and Richard Schmidtke of Deloitte draw on two cases in Germany and Israel revolving around differing interpretations concerning the delineation of transactions
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