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Direct Tax
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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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Anticipating potential changes in tax basis interpretations can help reduce audit risks in tax planning for intercompany equity transfers, says Abe Zhao of FenXun partners
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Sweeping changes are headed for Germany’s TP system in the New Year. Tax teams will need to be well-prepared, say Andreas Katz and Anna Kupprion of Kreston Bansbach
Sponsored Features
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Sponsored by CuatrecasasA spate of reforms has added to the growing appeal of Portuguese alternative investment funds. José Maria Cabral Sacadura and Francisco Soares Machado of Cuatrecasas explain the various vehicles available and the applicable tax framework
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Sponsored by DeloitteHenrik Karlsson, indirect tax leader – Nordics, Deloitte Sweden
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Sponsored by DeloitteInterview with Chijioke Odo, Africa tax and legal partner and West Africa indirect tax leader, Deloitte Africa
Special Focus
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Sponsored by DeloitteNicola Lostumbo and Jie Pan of Deloitte provide insights into high-value intercompany service charges, their role in creating value, and the most common tax authority challenges, before concluding with some considerations in mitigating risks
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Sponsored by DeloitteJobst Wilmanns and Anodri Suchdeve of Deloitte Germany introduce this year’s ITR guide presenting transfer pricing insights across several industries, with analysis from Deloitte’s transfer pricing industry experts and factoring in global economic changes
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Sponsored by DeloitteRalf Heussner of Deloitte Japan and Aaron Lee of Deloitte Singapore examine the latest transfer pricing trends impacting the banking sector in view of the implementation of the new Basel accord from 2025
Local Insights
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Sponsored by EY RomaniaClaudia Sofianu and Dan Răut of EY Romania discuss the growing challenges of cross-border teleworking, highlighting the complexities of taxation rights and the need for clearer and more unified EU regulations
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Sponsored by GNV ConsultingEndy Arya Yoga and Nanda Atsatalada of GNV Consulting summarise legislative updates concerning corporate income tax reduction facilities, bad debt expense deductions from gross income, and implementation of the Core Tax Administration System
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Sponsored by VRMA AdvogadosPaulo Victor Vieira da Rocha and Murilo Jakuk of VRMA Advogados discuss a recent decision by the Brazilian Supreme Court that ensures proportionality in tax penalties and strengthens legal protections for businesses