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Direct Tax
Technology is on the way to relieve tax advisers tired by onerous pillar two preparations, says Russell Gammon of Tax Systems
November 20, 2024
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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 -
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 DeloitteShaun Austin, Darcy Alamuddin, and Ryan McMahon of Deloitte analyse the feedback from the 2024 Deloitte transfer pricing controversy survey, highlighting key trends in the transfer pricing controversy space
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Sponsored by Kambourov & Partners Tax ConsultingDennitsa Dimitrova of Kambourov & Partners Tax Consulting highlights a significant tax risk in M&A transactions involving telecommunications operators and suggests what steps should be taken during the due diligence process
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Sponsored by DeloitteMariusz Każuch, Inka Traeger, and Conrad Marburg of Deloitte consider tax authorities' recharacterisation of intercompany transactions through drawing on recent practice in Poland and Germany, and suggest proactive measures global businesses can take
Local Insights
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Sponsored by Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici analyse the options excercised and choices made by Italy when transposing the provisions of the Public Country-by-Country Reporting Directive
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Sponsored by VRMA AdvogadosThe Supreme Federal Court has returned to a case that could have a huge economic impact on the federal government, report Paulo Victor Vieira da Rocha and Camila Montenegro Cruz of VRMA Advogados
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Sponsored by MDDPMagdalena Marciniak and Agnieszka Krzyżaniak of MDDP consider whether two recent rulings indicate that Polish taxpayers can look forward to a more positive landscape for transfer pricing adjustments
