Nouran Ibrahim and Karim Adel of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt say mutual agreement procedures will have a vital role to play as the country modernises its tax infrastructure

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

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

Endy Arya Yoga and Nanda Atsatalada of GNV Consulting summarise legislative updates concerning corporate income tax reduction facilities, bad debt expense deductions from gross income, and implementation of the Core Tax Administration System

Karanjot Singh Khurana, Devashish Jain, and Kanika Jain of Lakshmikumaran & Sridharan examine a ruling requiring multinational enterprises to pay taxes on profits attributed to their permanent establishment in India, despite global losses

Jun Au of DLA Piper Australia summarises the Australian Taxation Office’s newly set out considerations in deciding whether to examine a debt restructure and the key tax rules concerning corporate collective investment vehicles

Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente analyse a transfer pricing-related ruling by the Italian Supreme Court that effectively clarifies the role of OECD guidelines and the ‘best method’ rule

Paolo Ludovici and Andrea Iannaccone of Gatti Pavesi Bianchi Ludovici consider whether the regional tax on productive activities applicable to dividends distributed by subsidiaries to Italian parent companies conflicts with EU and constitutional principles

Joana Sequeira and Nadine Gomes of Vieira de Almeida & Associados explain recent developments in the Portuguese tax authorities’ stance on investment income assessment for partial redemptions of life insurance products

Paulo Victor Vieira da Rocha and Murilo Jakuk of VRMA Advogados discuss a recent decision by the Brazilian Supreme Court that ensures proportionality in tax penalties and strengthens legal protections for businesses

Paulo Victor Vieira da Rocha and Murilo Jakuk of VRMA Advogados discuss the recently published Provisional Measure 1262/24 and Normative Instruction 2228/24 as a statement of Brazil's commitment to the OECD's global tax standards

Carlos Jorge Vargas and Rodrigo Gómez Sánchez of Mascareño Vargas – Asesores explore Paraguay’s appeal to international investors and highlight the country’s competitive tax regime as a particularly significant factor in attracting foreign capital

Henriette Fuchs of Yaron-Eldar, Paller, Schwartz & Co in Tel Aviv reports on two substantial new tax benefits designed to stimulate and preserve continued investment in technology companies

Henriette Fuchs of Yaron-Eldar, Paller, Schwartz & Co in Tel Aviv concludes the follow-up article on SAFE investments in Israel, outlining the relative certainty of walking the safe “green path”.

In the first of a two-part article, Henriette Fuchs of Yaron-Eldar, Paller, Schwartz & Co in Tel Aviv reports on Israel tax authorities’ acceptance of the SAFE for investment in innovative and tech companies.

Michael Bernard of Vertex says adapting to the US’s challenging tax regime relies on an understanding of what is known as the nexus principle

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

Mark Martin and Thomas Bettge of KPMG in the US discuss the recent amount B consensus document and the associated compliance challenges

Dinko Dinev and Adam Wojewoda of Deloitte Luxembourg explore AI’s potential to enhance efficiency in transfer pricing but emphasise the irreplaceable value of human expertise in navigating complex regulatory landscapes

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

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