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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 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 DLA Piper NetherlandsThe application of real estate transfer tax to share acquisitions in real estate companies is set to become more frequent. Luca van Silfhout of DLA Piper Netherlands discusses the changes and suggests a mitigating strategy
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Sponsored by GNV ConsultingHartiadi Budi Santoso and Yoan Putra Muda of GNV Consulting report on a new regulation designed to stimulate Indonesia’s housing sector, and the modernisation of tax services through the Core Tax Administration System
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Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente explain how taxpayers can gain extra time to complete transfer pricing documentation and thus take advantage of Italy’s ‘penalty protection regime’