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Direct Tax
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Under the merged scheme for R&D tax relief introduced last year, rules on contracted out R&D have changed. James Dudbridge argues for a proactive approach when reviewing companies’ commercial arrangements
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Updated rules represent a significant shift in the Luxembourg TP landscape and emphasise the need for robust arm’s-length calculations, says Vanessa Ramos Ferrin of TransFair Pricing Solutions
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A recent UK First-tier Tribunal decision highlights the broad application of an anti-avoidance rule to deny tax relief, say Robert Waterson and Matthew Cummings of Eversheds Sutherland
Sponsored Features
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Sponsored by DeloitteAlicia Janisch, vice chair and US healthcare sector leader, Deloitte Tax LLP
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Sponsored by DeloitteMaria Paula Moreira, partner, Tax, Deloitte S-LATAM
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Sponsored by DeloitteDoris Gichuru, Africa Tax & Legal transfer pricing partner (Kenya), 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 DeloitteVrajesh Dutia and Michael Nixon of Deloitte explain the nuances of amount B as jurisdictions consider its adoption, and outline the uncertainties and challenges involved
Local Insights
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Sponsored by EY RomaniaClaudia Sofianu and Dan Răuț of EY Romania summarise the new directive on platform work and call for Romania to continue its drive towards increased tax compliance and reduced tax evasion in this area
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Sponsored by PwC ChileSandra Benedetto and Jonatan Israel of PwC Chile provide an overview of a law establishing a new legal concept that aligns taxation with ESG principles, and consider its implications for Chilean companies
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Sponsored by Lakshmikumaran & SridharanS Sriram and Dinesh Kukreja of Lakshmikumaran and Sridharan examine the tax consequences of foreign business reorganisations in India, including indirect transfer rules, statutory exemptions, and treaty benefits for multinational companies