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Francisco Cabral Matos and Francisca de Landerset of VdA examine Portugal’s tax neutrality regime for mergers and demergers, highlighting how rigid interpretations by the tax authority are undermining its practical application

Interview with Mauricio Martínez D’Meza, S-LATAM tax controversy leader, Deloitte Mexico

Paulo Victor Vieira da Rocha and Marina Fernandes of VRMA Advogados discuss a landmark trial at Brazil’s Federal Supreme Court on the taxation of profits earned by foreign subsidiaries and affiliated companies

Karanjot Singh Khurana, Prachi Bharadwaj, and Vrinda Agrawal of Lakshmikumaran & Sridharan analyse the tax deduction challenges arising when employee stock option plans are implemented via trusts

Paolo Ludovici and Andrea Iannaccone of Gatti Pavesi Bianchi Ludovici analyse an Italian Supreme Court decision that addresses the tax treaty concept of a fixed base, highlighting concerns over legal certainty and double taxation

Rafael Calvo and Adrián Arroyo of Garrigues Madrid discuss a National Court judgment clarifying that interest on equity (JSCP) received from Brazilian entities qualifies for an exemption under the Spain–Brazil double tax treaty

Marco Sandoli and Lorenzo Marantonio of Alma LED challenge the Revenue Agency’s ‘unsupportable’ interpretation on tax exemptions for business and shareholding transfers through trusts when taxation is applied at the time of asset segregation

Monika Marta Dziedzic, Paweł Wyciślik, and Bartosz Głowacki of MDDP highlight key Polish rulings on permanent establishment, offering guidance for foreign companies assessing corporate tax risks linked to local employees, office space, and remote work

The government’s proposed VAT reforms for residential property construction and rehabilitation are eagerly anticipated, says André Areias of Cuatrecasas, who emphasises the urgent need to review a ‘complex and outdated system’