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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 Tax PartnerMonika Bieri and Daniel Schönenberger of Tax Partner AG analyse a recent Federal Administrative Court case and its implications for current transfer pricing practice in Switzerland
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Sponsored by YulchonWith South Korea expected to take a more aggressive approach to auditing, tax partners from Yulchon analyse four transfer pricing-related rulings that provide guidance for multinationals
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Sponsored by Chevez Ruiz ZamarripaOscar Campero, Yoshio Uehara, and José Luis Iglesias of Chevez Ruiz Zamarripa provide a guide to the most commonly scrutinised concepts and the documentation required by the Mexican tax authority in transfer pricing audits
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