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While the rule could result in enhanced tax revenues, Egypt must consider its effect on foreign direct investment, say Rabie Morsy, Karim Adel, and Sandra Aziz of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt

Paolo 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

The 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

Magdalena 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

Jock McCormack of DLA Piper Australia summarises Australia’s latest proposed double tax agreement as the country’s treaty reforms gather pace, and potential changes to the non-resident capital gains tax withholding rate and threshold

Deloitte’s Tax Transformation Trends survey has highlighted key considerations for organisations shaping their talent strategies. Mary Fabean, Gina Salama, and Michelle Tariq of Deloitte suggest five ways to adapt to a rapidly changing tax environment

This month’s summary, by Ahdianto Ah and Reza Farhan of GNV Consulting, also explains a regulation providing for an import duty exemption on certain seeds and seedlings, and new supervisory powers for customs officials

Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente report on a ruling by the Italian Tax Agency and explain an update to the deadline for the submission of income tax returns

Fernando Matesanz of Spanish VAT Services casts a critical eye over the ‘odd and complex’ implementation of a new system that is designed to simplify Spain’s corrective VAT returns process

Gabriel Caldiron Rezende of Machado Associados explains the contrasting viewpoints and legislative developments regarding the taxation of goods moved between branches of the same company

Join ITR and insightsoftware at 2pm BST (3pm CEST) on September 24 to hear senior tax experts from KPMG Canada explain the evolving pillar two requirements and the transitional safe harbours – and consider what comes next

S Vasudevan and Harshit Khurana of Lakshmikumaran & Sridharan consider the winners and losers as India removes the 2% equalisation levy on overseas e-commerce operators to facilitate its implementation of the OECD’s pillar one solution

Maria 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

Jian-Cheng Ku and Roland Kleimann of DLA Piper Netherlands analyse how corporate reorganisations involving Dutch entities are impacted by the ‘excessive severance payment levy’

Jobst Wilmanns and Anodri Suchdeve of Deloitte preview a guide to the latest transfer pricing trends, produced in collaboration between ITR and global transfer pricing industry experts from Deloitte

Paolo 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

Aditya Hans, Ashish Jain, and Nilesh Chandak of Dhruva Advisors provide an update on India’s implementation of the OECD’s tax reforms after the Union Budget 2024–25 and consider the GloBE rules’ potential impact

Amit Bhalla and Andrew Jackomos of HLB Thailand explain the Thai Revenue Code’s guidance in determining the nature of the relationship between two entities and whether transfer pricing disclosure forms are required

Charles Setia Oetomo and Erviyanti Adam of GNV Consulting report that 37 types of administrative tax services can now be accessed using various ID numbers, and Indonesia has also updated several tax treaties

Federico Vincenti and Carola Valente of Crowe Valente/Valente Associati GEB Partners consider the ramifications of a ruling concerning the inclusion of loss-making companies in a transfer pricing benchmarking analysis as comparable entities

Adam Smith of DLA Piper Australia reviews a raft of proposed Australian tax law changes, including a widened scope of capital gains tax for foreign residents

Fernando Matesanz of Spanish VAT Services reports on a pronouncement by an EU member state on the impact that transfer pricing adjustments have on the VAT applied to transactions

Piotr Paśko and Tomasz Janik of MDDP say that while application of the tax exemption has historically been challenging, foreign investment vehicles stand to benefit as a more favourable environment appears to be emerging

Paolo Ludovici and Michele Bissoli of Gatti Pavesi Bianchi Ludovici examine the new ‘reshoring regime’, a set of tax incentives and benefits aimed at encouraging companies to relocate their operations back to Italy

Santiago Llano Zapatero and Fernando Caballero Gout of Ritch Mueller examine the state-imposed taxes applicable to specific transactions in certain states in Mexico

Join Dhruva Advisors, Taxsutra, and ITR from 12.30pm–2pm BST (5pm–6.30pm India Standard Time) on July 23 to hear expert analysis of the implications of the tax proposals in India’s 2024–25 budget

Paulo Victor Vieira da Rocha and Murilo Jakuk of VRMA Advogados discuss treaty articles 12 and 13 within the context of national case law concerning the taxation of fees paid for imported technical services

Maria Andersson Berg of KPMG Sweden explains the main proposed amendments and says joint calculation of the deduction base and net interest income will create a more favourable system for most groups

Application of the GloBE rules will present a challenge for the Polish legislature as it seeks to maintain the country’s appeal as an investment location, say Monika Marta Dziedzic and Łukasz Kumkowski of MDDP

Vítor Loureiro e Silva and Duarte Canau of Vieira de Almeida & Associados discuss the key aspects of the Portuguese exemption waiver regime and whether it is in accordance with EU law and principles

Fabian Abi Cakra and Aditya Nugroho of GNV Consulting report that Indonesia’s reservations now cover 13 countries, while new regulations have addressed export duty rates for metal mineral products and tax administration systems

Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente explain the benefits and recently updated provisions of the cooperative compliance regime

Jock McCormack and Jun Au lead off DLA Piper Australia’s monthly roundup by explaining the significance of the Full Federal Court overturning a decision concerning royalty withholding tax and diverted profits tax

Karanjot Singh Khurana of Lakshmikumaran & Sridharan presents an Indian perspective on the transfer pricing implications of multinational corporations entering into global contracts that could affect group entities

With 45 states imposing a sales tax, Michael Bernard of Vertex explains the key points to note for European businesses aiming to broaden their market and capitalise on the e-commerce boom in the US

Ichwan Sukardi and T Qivi Hady Daholi of RSM Indonesia consider the Directorate General of Taxes’ increasing reliance on technology in transfer pricing evaluation, litigation developments in the area, resolution mechanisms, and mitigation strategies

Paulo Victor Vieira da Rocha and Murilo Jakuk of VRMA Advogados discuss Provisional Measure No. 1,227, which introduces new parameters for tax benefits and imposes significant limitations on the compensation of PIS and COFINS credits

A change of president is not expected to alter the aggressive stance of the tax authorities, say Oscar López Velarde Perez, Juan José Paullada Eguirao, and Gabriel Márquez García of Ritch Mueller

The insights of senior tax practitioners of Deloitte on recent practice in Argentina, Uruguay, Peru, and Colombia indicate an increasing amount of transfer pricing audit activity and a need for early preparation by taxpayers

Revised transfer pricing and permanent establishment compliance requirements are leading multinational corporations to consider the reorganisation of the maquiladora operating model through business restructuring, say Simón Somohano and Francisco Díaz of Deloitte S-LATAM

Mario Coyoy of Deloitte S-LATAM and Michelle Martinelli of Deloitte Panama note increasing transfer pricing scrutiny in several Central American jurisdictions as they step up their attempts to enhance transparency and ensure compliance

Vanesa Lanciotti of Deloitte Chile explains the country’s key transfer pricing-related measures as it seeks to increase its tax collection by 1.5% of GDP, with a new focus on tax compliance and financial governance

Luis Carlos Pérez Gómez Ramírez and Víctor Hugo Bretado Fernández of Copper Wolf explain the context of a Mexican Supreme Court of Justice ruling concerning the revised approach to calculating statutory profit sharing distributions

Gabriel Caldiron Rezende of Machado Associados discusses the new regulation concerning the declaration of tax benefits and the additional – and unnecessary – difficulties for taxpayers

Carlos Ayub of Deloitte Brazil focuses on the challenges for organisations that trade commodities under the country’s new transfer pricing legislation and explains what methods and courses of action are available to in-scope taxpayers

Paolo Ludovici and Pietro Bricchetto of Gatti Pavesi Bianchi Ludovici examine the Italian tax authorities’ interpretative position concerning the VAT regime applicable to dispute financing services provided within the framework of third-party litigation funding agreements

Join ITR and insightsoftware at 1pm BST (2pm CEST) on July 18 to hear how the gap between technology and finance can be addressed through transforming your tax processes and saying goodbye to disconnected systems

João Riscado Rapoula and Luís Maria of Vieira de Almeida & Associados conduct an in-depth analysis of the Portuguese and Angolan general anti-abuse rules, with a particular focus on the similarities and differences

Raghavan Ramabadran, Charulatha Rajaji, and Raghav Rajeev of Lakshmikumaran & Sridharan conclude their analysis of goods and services tax litigation in India by explaining the critical importance of how pre-assessment or assessment proceedings are conducted

Joaquim Pedro Lampreia and Miguel Gonzalez Amado of Vieira de Almeida welcome the Portuguese Supreme Administrative Court’s clarification that a ‘pure’ holding company does not qualify for a stamp tax exemption on credit operations

Updated build-to-rent tax concession proposals should encourage foreign investment, but the strict eligibility requirements will restrict the number of qualifying projects, say Jock McCormack and Eddie Ahn of DLA Piper Australia

Miruna Enache of EY Romania reports on the country’s bold introduction of a minimum turnover tax as its digital tax transformation continues apace, while the potential adoption of progressive taxation is still hotly debated

Issues and opportunities arising from the tax facility for foreign loans and grants for government projects could be key to the ‘Golden Indonesia’ dream, say I Dewa Made Agung Nugraha and Egar Adipratama of GNV Consulting

Indonesia aims to improve the efficiency of its commercial imports system and has issued several tax-related regulations in other areas recently, report I Dewa Made Agung Nugraha and Yoan Putra Muda of GNV Consulting

Fernando Matesanz of Spanish VAT Services reports on a domestic ruling that draws on CJEU case law concerning the tax treatment of professional services provided by a company's board members

Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente provide a guide to Italy’s transitional country-by-country reporting safe harbours for groups within the scope of the pillar two global minimum tax requirements

Silvan Guler and Thomas Zellweger of Tax Partner summarise Swiss collective investment schemes and their taxation, and assess the country’s appeal as an investment fund location after the introduction of limited qualified investor funds

Paul Ashburn, Amit Bhalla, and Urika Solano of HLB Thailand provide an update on Thailand’s progress towards implementation of BEPS 2.0 and explain why governmental agencies and multinational enterprises should undertake comprehensive reassessments

Multinational enterprises must include transfer pricing and cost accounting experts in taking an integrated approach to supporting the arm’s-length nature of intragroup service charges, say Enrique Marchesi-Herce, Gilles Andreini, and Serena Picariello of Deloitte Luxembourg

Senior EY tax practitioners provide an update on the pillar two roll-out timetables across the region and consider various example scenarios as they assess the likely impact on multinational enterprises in 2024 and beyond

Amanda Jern of KPMG Sweden says an annual tax transparency survey of 151 Nordic companies indicates reporting remains much the same, despite increasing pressure to report on tax

Lewis Lu of KPMG China looks at the recently passed Tariffs Law and the advancements in tax legislation

Paolo Ludovici and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici focus on how the simplified and streamlined approach set out in the OECD’s Pillar One – Amount B report enhances tax certainty

Taxation when companies acquire shares in entities that hold real estate can be a fiendishly complicated issue. Ricardo Seabra Moura of Morais Leitão, Galvão Teles, Soares da Silva & Associados summarises the regulations and interpretations

The discontinuation of a proposed measure to deny deductions for certain payments relating to intangibles is among several taxation updates in Australia’s federal budget, as summarised by senior tax practitioners from DLA Piper Australia

Ana Helena Farinha and Tiago Martins de Oliveira of Cuatrecasas provide an overview of the current status of the Portuguese warranty and indemnity insurance and tax insurance market

Marcel R Jung of MME Legal Tax Compliance explains the Swiss forfait tax regime, and cites the actor’s choice of his tax home as an indication of its long-standing attractiveness – and perhaps his fondness for fine chocolate

Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente suggest what documentation can demonstrate the reasonableness of the costs of an intra-group transaction, and the benefits for a subsidiary

Benjamin P Simatupang, Dwipa Abimanyu Dewantara, and Fajar Ramadhani of GNV Consulting highlight updated regulations and mandatory implementation of the Customs-Excise Information System and Automation 4.0 as Indonesia rings the changes

As the need for integrated tax data increases, Jennifer Deutsch of Deloitte Global explains why a trifecta of strategic investment, training, and maintenance is the best bet for tax leaders aiming to generate real-time insights

A multinational enterprise bearing the cost of an employee stock option plan granted to an Indian subsidiary creates several complexities, as explained by S Vasudevan, Harshit Khurana, and Sonali Bansal of Lakshmikumaran & Sridharan

Adrian Rus and Georgiana Bizdrigheanu of EY Romania explain the options for the country’s taxpayers in tackling double taxation and suggest how predictability and efficiency can be improved

With transfer pricing principles becoming increasingly important as start-ups expand, Nouran Ibrahim and Maureen Guirguis of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt explain the salient points and how to meet the challenges

Juan José Paullada Eguirao and Gabriel Márquez García of Ritch Mueller explain the consequences of a foreign entity being deemed to have created a permanent establishment, and how to negate that risk

Balazs Majoros of Deloitte Luxembourg provides an update on the transfer pricing landscape in the grand duchy against a backdrop of opposition to a draft bill and winds of change from the EU

The interest of other FIBRAs in a potential acquisition of the Terrafina real estate investment trust highlights a lack of taxation guidance in such transactions, say Oscar López Velarde and Regina Albornoz of Ritch Mueller

Starting this year, Thailand’s Revenue Department has revised its approach to taxing foreign income received by tax residents. Paul Ashburn of HLB Thailand summarises the changes

Fernando Matesanz of Spanish VAT Services welcomes a clear decision on how to categorise vouchers as the VAT treatment of such promotional schemes becomes ever more complex

Prachi Bhardwaj and S Vasudevan of Lakshmikumaran & Sridharan explain how tax treaty provisions concerning the allowability of deductions for Indian residents align with non-discrimination clauses

Paolo Ludovici and Luca Tortorella of Gatti Pavesi Bianchi Ludovici highlight two recent Italian tax court decisions regarding admissibility to mutual agreement procedures where the double taxation derives from self-adjustments rather than formal assessments

David Linke of KPMG International and Victoria Heard of KPMG in the UK say it is imperative for tax leaders to understand geopolitical events and social trends to chart a course through choppy waters

Multinational enterprises that conduct intra-group transactions in EU jurisdictions should be closely monitoring a proposed transfer pricing directive, say João Velez de Lima and André Vilaça Ferreira of Vieira de Almeida

The Spanish Supreme Court has confirmed its stance on the fiscal year in which income from a refund of taxes should be recognised, report Alejandro Fernández and Sandra Díaz of Garrigues Spain

Claudia Sofianu and Dan Răuț of EY Romania explain a new initiative by the European Parliament that aims to address the rights and taxation of ‘gig’ workers, and consider its potential impact on Romania

Lewis Lu of KPMG China reviews the recent efforts to enhance tax certainty and enforcement effectiveness

Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente analyse a significant addition to Italy’s case law on the application of transfer pricing regulations to interest-free loans between related parties

Jock McCormack of DLA Piper Australia reports on a new initiative that aims to stimulate Australia’s build-to-rent sector and address housing supply challenges through the offering of tax concessions for construction and investment

Endy Arya Yoga and Welly Armantha Napitupulu of GNV Consulting summarise recent updates in Indonesia’s tax system, including new debt-related guidelines in the customs and excise sectors and import policy changes

Gabriel Caldiron Rezende of Machado Associados discusses a highly questionable manoeuvre by the Brazilian Federal Revenue Service to boost tax collection, despite a decision by the Federal Supreme Court

André Areias and Liliana Piedade of Cuatrecasas report on a preliminary ruling request by the Portuguese Arbitral Court and consider the decision’s expected impact on taxpayers

An uptick in nearshoring activities in Mexico has led to heightened interest in trusts that specialise in energy and infrastructure investments. Federico Scheffler, Eduardo Espinosa, and Ileana García of Galicia Abogados explain the nuances

Ralf Heussner, Anodri Suchdeve, and Fangying Xu of Deloitte examine the transfer pricing challenges arising from an increasing number of intra-bank funding arrangements as stricter capital requirements trigger the attention of regulators and tax authorities

Monika Dziedzic and Łukasz Kumkowski of MDDP consider the dividend taxation exemption for payments made by Polish companies and explain the fulfilment of the beneficial ownership requirement by foreign holding companies

Lewis Lu and John Timpany of KPMG China report on the latest round of reviews of the EU’s list of non-cooperative jurisdictions for tax purposes, with Hong Kong now off the EU grey list

Tax and finance teams are adopting a working methodology pioneered by the tech world, says Peter Boerhof of Vertex

A case involving registration tax applied to a real estate contribution highlights the Italian tax framework’s inconsistency with the principles under a European directive, say Paolo Ludovici and Andrea Iannaccone of Gatti Pavesi Bianchi Ludovici

Gabriel Caldiron Rezende of Machado Associados comments on a bill of law presented by the Brazilian Congress that outlines a recently created ‘sin tax’ on goods and services considered harmful to health or the environment

Gregory Verpoorten and Rogier Vanhorick of Deloitte explain three key lessons for tax leaders as real-time indirect tax compliance moves ever closer and compliance requirements become even more complex

Jeklira Tampubolon and Julius Wahyu Daryono of GNV Consulting Services report on fresh VAT incentives designed to stimulate investment in the housing sector, and several regulations that are intended to boost electric vehicle adoption

Interview with Carolina Acuña, partner, Deloitte S-LATAM

Interview with Asiata Agboluaje, Africa tax and legal international tax and regulatory partner (Nigeria), Deloitte Africa

Interview with Maria Trakadi, partner and tax and legal leader, Deloitte Greece

Lewis Lu of KPMG China explains the recently announced Hetao–Hong Kong zone income tax incentives, which aim to boost science and technology innovation, and stimulate investment and collaboration between Shenzhen and Hong Kong

Interview with Betsy Evans, US tax business services leader, Deloitte Tax LLP

Join ITR and KPMG China at 10am BST (5pm Beijing time) on April 18 2024 for an analysis of the tax treatment of indirect share transfers in China, and insights into potential developments

Ichwan Sukardi and T Qivi Hady Daholi of RSM Indonesia explain the clarifications provided by the latest Indonesian transfer pricing regulation, but point out that uncertainty remains around several issues

Interview with Jo-Anne Anderson, partner, Deloitte Canada

Joaquim Pedro Lampreia and Carolina Telles Ferreira of Vieira de Almeida explain that Portugal’s tardiness in transposing the EU’s directive on administrative cooperation leaves online platform operators facing penalties through no fault of their own

Mark Martin and Thomas Bettge of KPMG in the US discuss the first published statistics on the International Compliance Assurance Programme and their implications for businesses looking to obtain tax certainty

Monika 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

In the first article of a two-part series on goods and services tax litigation in India, Raghavan Ramabadran, Charulatha Rajaji, and Raghav Rajeev of Lakshmikumaran & Sridharan consider the requirements concerning pre-assessment proceedings