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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 CuatrecasasMaria Inês Cotrim and Sofia Alves Pires of Cuatrecasas explain Portugal’s property transfer tax applied to share transfers and the tax authority’s interpretation of the non-allocation of real estate assets to economic activities requirement
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Sponsored by DLA Piper NetherlandsJian-Cheng Ku and Roland Kleimann of DLA Piper Netherlands analyse how corporate reorganisations involving Dutch entities are impacted by the ‘excessive severance payment levy’
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Sponsored by Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Daniel Canola of Gatti Pavesi Bianchi Ludovici highlight some noteworthy aspects of the envisaged introduction of a cross-border relief for tax losses in Italy, fostered by the CJEU’s case law
